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 - Ld. CIT without pointing out any infirmity in the reply /explanation of the assessee could not concluded that the assessment order passed by the AO was found to be ‘erroneous and prejudicial to the interest of revenue’ - explanation-2(a) to section 263 does not authorize or give unfettered powers to the Commissioner to revise each and every order
Revision u/s 263 - Ld. CIT without pointing out any infirmity in the reply /explanation of the assessee could not concluded that the assessment order passed by the AO was found to be ‘erroneous and prejudicial to the interest of revenue’ - explanation-2(a) to section 263 does not authorize or give unfettered powers to the Commissioner to revise each and every order
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