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 ...
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Reopening of assessment u/s 147 - Disallowance u/s. 40(a)(ia) - TDS on rent - Normally whenever any irregularity crept in the proceedings, then after removing the irregularities, proceedings is to be initiated from that stage but by remitting the issue to the ld. first appellate authority we would be multiplying the litigation, because the ld. CIT(A) would call for a remand report from the Assessing Officer and proceedings would commence on two stages in order to avoid that situation we would deem it proper to set aside order of both the revenue authorities and remit all the issues to the Assessing Officer. - AT
Reopening of assessment u/s 147 - Disallowance u/s. 40(a)(ia) - TDS on rent - Normally whenever any irregularity crept in the proceedings, then after removing the irregularities, proceedings is to be initiated from that stage but by remitting the issue to the ld. first appellate authority we would be multiplying the litigation, because the ld. CIT(A) would call for a remand report from the Assessing Officer and proceedings would commence on two stages in order to avoid that situation we would deem it proper to set aside order of both the revenue authorities and remit all the issues to the Assessing Officer. - AT
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