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 ...
Validity of reopening of assessment u/s 147 - sale of immovable property - In the absence of any development during this intervening period of one year from the date of purchase and till the date of sale, the appreciation of value from ₹ 4.00 lacs to ₹ 38.50 lacs indicates the involvement of the parties in mischievous acts of showing the minimum amount of purchase consideration by the assessee in comparison to the sale consideration shown in the sale agreement. - AT
Validity of reopening of assessment u/s 147 - sale of immovable property - In the absence of any development during this intervening period of one year from the date of purchase and till the date of sale, the appreciation of value from ₹ 4.00 lacs to ₹ 38.50 lacs indicates the involvement of the parties in mischievous acts of showing the minimum amount of purchase consideration by the assessee in comparison to the sale consideration shown in the sale agreement. - AT
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