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 ...
Assessment framed u/s.153A - computation of period of 6 years / 10 years in search cases - amendment of provisions of section 1153A(1)(b) - while computing ten assessment years, the starting point has to be the end of the search assessment year - CIT(A) rightly held that the 10th assessment year counted from this AY 2018-19 is AY 2009-10 and he held that notice issued u/s. 153A of the Act for AY 2008-09 could not have been issued. - AT
Assessment framed u/s.153A - computation of period of 6 years / 10 years in search cases - amendment of provisions of section 1153A(1)(b) - while computing ten assessment years, the starting point has to be the end of the search assessment year - CIT(A) rightly held that the 10th assessment year counted from this AY 2018-19 is AY 2009-10 and he held that notice issued u/s. 153A of the Act for AY 2008-09 could not have been issued. - AT
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