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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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Reopening of assessment u/s 147 - wrong facts in reasons recorded - AO completely ignored the fact that the return was already filed on 18.01.2010 and vide letter dated 24.02.2012 the assessee has explained that he is a regular assessee and produced the copy of Income-tax return filed - assumption of jurisdiction by the AO is bad in law
Reopening of assessment u/s 147 - wrong facts in reasons recorded - AO completely ignored the fact that the return was already filed on 18.01.2010 and vide letter dated 24.02.2012 the assessee has explained that he is a regular assessee and produced the copy of Income-tax return filed - assumption of jurisdiction by the AO is bad in law
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