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 assessment made under Section 143(1) instead of section 153C - In the facts of the present appeal, undisputedly, the books of account/documents/assets found during the search and seizure operation were received by the AO having jurisdiction over the assessee - Neither the AO has recorded any satisfaction nor issued any notice as contemplated under section 153C - The impugned assessment order passed under section 143(3) of the Act is invalid. - AT
Validity of assessment made under Section 143(1) instead of section 153C - In the facts of the present appeal, undisputedly, the books of account/documents/assets found during the search and seizure operation were received by the AO having jurisdiction over the assessee - Neither the AO has recorded any satisfaction nor issued any notice as contemplated under section 153C - The impugned assessment order passed under section 143(3) of the Act is invalid. - AT
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