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 - Income deemed to accrue or arise in India - writ against the show cause notice - Looking into the spirit of Section 9(1)(i) of the Act, in the context of the contents made in the show cause notice, it is sufficient to form an opinion that the matter requires effective and elaborate adjudication in order to cull out the truth with reference to the pleadings and grounds raised by the petitioner. - HC
Reopening of assessment u/s 147 - Income deemed to accrue or arise in India - writ against the show cause notice - Looking into the spirit of Section 9(1)(i) of the Act, in the context of the contents made in the show cause notice, it is sufficient to form an opinion that the matter requires effective and elaborate adjudication in order to cull out the truth with reference to the pleadings and grounds raised by the petitioner. - HC
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