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 ...
Time limit for completion of assessment - scope of the term "Direction" u/s 153 - it must be express direction necessary for disposal of the case before the authority or Court. It must also be a direction which the authority or Court is empowered to give while deciding case before it. The expressions “findings” and “direction” in Section 153(3)(ii) must be accordingly confined. Section 153(3)(ii) is not a provision enlarging the jurisdiction of the authority or Court.
Time limit for completion of assessment - scope of the term "Direction" u/s 153 - it must be express direction necessary for disposal of the case before the authority or Court. It must also be a direction which the authority or Court is empowered to give while deciding case before it. The expressions “findings” and “direction” in Section 153(3)(ii) must be accordingly confined. Section 153(3)(ii) is not a provision enlarging the jurisdiction of the authority or Court.
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