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...
Validity of assessment - Non issuing of notice u/s 143(2) - Applicability of provisions of section 292BB - Before the Tribunal the AR could not submit any proof for having raised the objections before the completion of the assessment. From the evidences perused there is nothing to prove that the objection were raised before AO for non issue of notice u/s.143(2) to take shelter under proviso to 292BB and that there is no contrary evidence submitted to support the claim that the notice u/s.143(2) was not served on the assessee. - AT
Validity of assessment - Non issuing of notice u/s 143(2) - Applicability of provisions of section 292BB - Before the Tribunal the AR could not submit any proof for having raised the objections before the completion of the assessment. From the evidences perused there is nothing to prove that the objection were raised before AO for non issue of notice u/s.143(2) to take shelter under proviso to 292BB and that there is no contrary evidence submitted to support the claim that the notice u/s.143(2) was not served on the assessee. - AT
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