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 ...
Reopening of assessment u/s 147 - Deduction u/s 80IB(10) - built-up area of some of the residential units in the project was more than the prescribed area of 1000 sq. ft - the reopening of the case before us was carried out on the basis of fresh “tangible material” which clearly established that the A.O had a ‘reason to believe’ that the income of the assessee chargeable to tax had escaped assessment.
Reopening of assessment u/s 147 - Deduction u/s 80IB(10) - built-up area of some of the residential units in the project was more than the prescribed area of 1000 sq. ft - the reopening of the case before us was carried out on the basis of fresh “tangible material” which clearly established that the A.O had a ‘reason to believe’ that the income of the assessee chargeable to tax had escaped assessment.
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