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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Revision u/s 263 - deduction under section 54B - No doubt the assessee declared capital gain but, whether its exemption can be claimed on purchase of other agriculture land, is not at all examined by the AO - the ld. PCIT validly assumed his jurisdiction for exercising his power u/s 263 by taking view that the order passed by AO is erroneous and in so far as prejudicial to the interest of justice. - Facts remained that the ld. PCIT passed the impugned order without considering various pleas of the assessee raised in its reply. - Matter restored back - AT
Revision u/s 263 - deduction under section 54B - No doubt the assessee declared capital gain but, whether its exemption can be claimed on purchase of other agriculture land, is not at all examined by the AO - the ld. PCIT validly assumed his jurisdiction for exercising his power u/s 263 by taking view that the order passed by AO is erroneous and in so far as prejudicial to the interest of justice. - Facts remained that the ld. PCIT passed the impugned order without considering various pleas of the assessee raised in its reply. - Matter restored back - AT
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