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 ...
Reassessment notice u/s 148 - “reason to believe" must be interpreted that the AO on receipt of any such new material or materials in relation to the non furnishing of fact by the assessee has made out a prima facie opinion that it is the case for reopening of the assessment - in the absence of having knowledge about the reasons, the petitioners cannot come to the conclusion that there is no new material or reason to reopen the assessment - writ dismissed
Reassessment notice u/s 148 - “reason to believe" must be interpreted that the AO on receipt of any such new material or materials in relation to the non furnishing of fact by the assessee has made out a prima facie opinion that it is the case for reopening of the assessment - in the absence of having knowledge about the reasons, the petitioners cannot come to the conclusion that there is no new material or reason to reopen the assessment - writ dismissed
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