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 ...
Validity of assessment u/s 158BC r.w.s. 158D - The satisfaction recorded by the AO as per Revenue is incorporated in the order sheet and not in the notice. Thus, it is not a valid satisfaction, as satisfaction u/s 158BD has to be recorded by the AO of the searched person and not by the AO of the other person i.e. assessee.
Validity of assessment u/s 158BC r.w.s. 158D - The satisfaction recorded by the AO as per Revenue is incorporated in the order sheet and not in the notice. Thus, it is not a valid satisfaction, as satisfaction u/s 158BD has to be recorded by the AO of the searched person and not by the AO of the other person i.e. assessee.
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