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 ...
Provisions relating to reassessment proceedings - It has been proposed that the section 148 of the Act may be amended to provide that a return in response to a notice u/s 148 of the Act shall be furnished within three months from the end of the month in which such notice is issued, or within such further time as may be allowed by the AO on a request made in this behalf by the assessee. However, any return which is furnished beyond the period allowed in the section 148 to furnish such return of income shall not be deemed to be a return u/s 139 of the Act. As a result, the consequential requirements viz. notice under section 143(2) etc. would not be mandatory for such returns.
Provisions relating to reassessment proceedings - It has been proposed that the section 148 of the Act may be amended to provide that a return in response to a notice u/s 148 of the Act shall be furnished within three months from the end of the month in which such notice is issued, or within such further time as may be allowed by the AO on a request made in this behalf by the assessee. However, any return which is furnished beyond the period allowed in the section 148 to furnish such return of income shall not be deemed to be a return u/s 139 of the Act. As a result, the consequential requirements viz. notice under section 143(2) etc. would not be mandatory for such returns.
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