Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Revision u/s 263 - Period of limitation - if the issue on which the proceedings u/s 263 is initiated is not a subject matter of the assessment order passed u/s 143(3) r/w 147, then the limitation period has to be reckoned from the original assessment order passed u/s 143(3) or if the return of income was processed u/s 143(1), then from the date of intimation u/s 143(1)
Revision u/s 263 - Period of limitation - if the issue on which the proceedings u/s 263 is initiated is not a subject matter of the assessment order passed u/s 143(3) r/w 147, then the limitation period has to be reckoned from the original assessment order passed u/s 143(3) or if the return of income was processed u/s 143(1), then from the date of intimation u/s 143(1)
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