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 ...
Rectification of mistake - ITAT has allows appeal on merit & dismissed the assessee’s cross objections as infructuous regarding re-opening of assessment. Assesse not challenged that order. After reversal of appeal by High court on merit assesse filed rectification application before Tribunal. High Court held that rectification application filed by the assessee was barred by the principle of finality, and to an extent the doctrine of merger. High Court further held that this is not apparent mistake or error warranting rectification.
Rectification of mistake - ITAT has allows appeal on merit & dismissed the assessee’s cross objections as infructuous regarding re-opening of assessment. Assesse not challenged that order. After reversal of appeal by High court on merit assesse filed rectification application before Tribunal. High Court held that rectification application filed by the assessee was barred by the principle of finality, and to an extent the doctrine of merger. High Court further held that this is not apparent mistake or error warranting rectification.
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