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 - validity of reasons to believe - undisclosed profit - No approval sought from the Additional Commissioner/Commissioner of Incometax for issuance of notice u/s 148 - The impugned order rejecting the objections, the Assessing Officer has recorded that the mistake has happened in mostly all the cases reopened during the year because the cases were reopened on the information based and also of nonfilers which depicts that the Assessing Officer has mechanically recorded the reasons without properly appreciating the facts of the case. - HC
Reopening of assessment u/s 147 - validity of reasons to believe - undisclosed profit - No approval sought from the Additional Commissioner/Commissioner of Incometax for issuance of notice u/s 148 - The impugned order rejecting the objections, the Assessing Officer has recorded that the mistake has happened in mostly all the cases reopened during the year because the cases were reopened on the information based and also of nonfilers which depicts that the Assessing Officer has mechanically recorded the reasons without properly appreciating the facts of the case. - HC
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