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...
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Reopening of assessment u/s 147 - Principles of natural justice - this Court is of an opinion that the opportunity provided by the respondent to the petitioner was not properly utilised, but they have utilised the same for the purpose of prolonging the proceedings. Therefore, this Court is of the considered opinion that the principles of natural justice has not been violated in this case, but the opportunities provided are not properly utilised by the petitioner, for which the respondent cannot be faulted. WP dismissed. - HC
Reopening of assessment u/s 147 - Principles of natural justice - this Court is of an opinion that the opportunity provided by the respondent to the petitioner was not properly utilised, but they have utilised the same for the purpose of prolonging the proceedings. Therefore, this Court is of the considered opinion that the principles of natural justice has not been violated in this case, but the opportunities provided are not properly utilised by the petitioner, for which the respondent cannot be faulted. WP dismissed. - HC
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