Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Rental receipts credited, accounted for and assessed in a registered partnership firm's hands remain taxable to the firm; partners' capital-account withdrawals do not constitute rental income or transfer ownership of the building. Under a registered joint development agreement granting the developer effective possession, dominion and authority over the property, transfer occurs on execution of the agreement rather than on later delivery of constructed area. The special capital-gains regime for joint development agreements operates prospectively and does not apply to earlier transactions. Rough, unparticularised loose sheets without independent corroboration cannot support additions for undisclosed or underreported rental income. The rental-income additions were deleted and later-year capital-gains additions were set aside.
Rental receipts credited, accounted for and assessed in a registered partnership firm's hands remain taxable to the firm; partners' capital-account withdrawals do not constitute rental income or transfer ownership of the building. Under a registered joint development agreement granting the developer effective possession, dominion and authority over the property, transfer occurs on execution of the agreement rather than on later delivery of constructed area. The special capital-gains regime for joint development agreements operates prospectively and does not apply to earlier transactions. Rough, unparticularised loose sheets without independent corroboration cannot support additions for undisclosed or underreported rental income. The rental-income additions were deleted and later-year capital-gains additions were set aside.
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