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 ...
Exemption u/s 11 - Reopening of assessment u/s 147 - whether jurisdiction was vested on the ld. CIT(E) and not with the Territorial Commissioner? - the registration U/s 12AA is in action from the year of application. So, the year of application is considered as deemed registration and the claim of deduction u/s 11 and 12 should be applicable accordingly. Accordingly, the assessing authority had acted beyond jurisdiction. - AT
Exemption u/s 11 - Reopening of assessment u/s 147 - whether jurisdiction was vested on the ld. CIT(E) and not with the Territorial Commissioner? - the registration U/s 12AA is in action from the year of application. So, the year of application is considered as deemed registration and the claim of deduction u/s 11 and 12 should be applicable accordingly. Accordingly, the assessing authority had acted beyond jurisdiction. - AT
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