Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Accrual of income - Since the stock-in-trade has only been contributed and has not been sold during the relevant AY, there is no receipt or accrual of business receipt during the relevant AY. - the authorities below indeed erred in bringing to tax the anticipated business profits on assessee’s entering into a development agreement (JDA) in respect of the land held by the assessee as stock in trade.
Accrual of income - Since the stock-in-trade has only been contributed and has not been sold during the relevant AY, there is no receipt or accrual of business receipt during the relevant AY. - the authorities below indeed erred in bringing to tax the anticipated business profits on assessee’s entering into a development agreement (JDA) in respect of the land held by the assessee as stock in trade.
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