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 - Initiation of reassessment proceedings, u/s.148 of the Act and issued notice to the assessee was based on valid reason on the strength of new tangible material which was not before the AO during the original assessment proceedings. Therefore, we are unable to see any ambiguity, perversity or invalidity in the action of the AO in initiating reassessment proceedings, issuing notice u/s.148 of the Act and framing reassessment order u/s.143(3) r.w.s.147 of the Act. - AT
Reopening of assessment u/s 147 - Initiation of reassessment proceedings, u/s.148 of the Act and issued notice to the assessee was based on valid reason on the strength of new tangible material which was not before the AO during the original assessment proceedings. Therefore, we are unable to see any ambiguity, perversity or invalidity in the action of the AO in initiating reassessment proceedings, issuing notice u/s.148 of the Act and framing reassessment order u/s.143(3) r.w.s.147 of the Act. - AT
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