Capital Asset Conversion Requires Proven Business Stock Treatment; Paper Consideration in Spousal Flat Transfers Does Not Create Taxable Business Inco...
Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuin...
Commercial property status protects capital-gains exemption when residential-house ownership limits are tested, while agricultural-land character gove...
Investigation deposits refunded after failed customs demands fall outside the statutory appellate pre-deposit interest regime and may attract compensa...
Resolution plan finality extinguishes unquantified operational-creditor claims and pending proceedings unless the approved plan expressly preserves th...
Jurisdiction by AO to suo-moto convert protective assessment into substantive assessment post completion of original assessment proceedings - Once the ld CIT(A) was ceased of the matter, the AO could have brought this up before the ld CIT(A) and sought necessary directions. Where however, the AO still hold the belief to take suo-moto action to convert protective assessment into substantive assessment, he could have invoked his jurisdiction in terms of section 147 on satisfaction of conditions specified therein and in absence of thereof, the present action of the AO cannot be sustained in the eyes of law. - AT
Jurisdiction by AO to suo-moto convert protective assessment into substantive assessment post completion of original assessment proceedings - Once the ld CIT(A) was ceased of the matter, the AO could have brought this up before the ld CIT(A) and sought necessary directions. Where however, the AO still hold the belief to take suo-moto action to convert protective assessment into substantive assessment, he could have invoked his jurisdiction in terms of section 147 on satisfaction of conditions specified therein and in absence of thereof, the present action of the AO cannot be sustained in the eyes of law. - AT
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TaxTMI 
TaxTMI 
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