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 ...
Validity of jurisdiction assumed by AO u/s 147 - Assessment was not complete based not valuation report - While a formal rejection of books may not, at times, be possibly necessary an abstract position of law, an implied dissatisfaction on the books could not be gauged either from the original assessment or from the attendant office note. - CIT(A) has also made reference to various other judgments and has come to the conclusion that ingredients of Section 147 of the Act are not fulfilled in the instant case and consequently reopening is not permissible in the facts and circumstances of the case - AT
Validity of jurisdiction assumed by AO u/s 147 - Assessment was not complete based not valuation report - While a formal rejection of books may not, at times, be possibly necessary an abstract position of law, an implied dissatisfaction on the books could not be gauged either from the original assessment or from the attendant office note. - CIT(A) has also made reference to various other judgments and has come to the conclusion that ingredients of Section 147 of the Act are not fulfilled in the instant case and consequently reopening is not permissible in the facts and circumstances of the case - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
