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 u/s 153C - Since a response was on record, undoubtedly, the AO was required to issue a notice under Section 143(2) of the Act and then proceed further in the matter, and perhaps thereafter, frame an assessment u/s 147 read with Section 144 of the Act. This was not done. - for the AO to take recourse to Section 144 of the Act was completely uncalled. - HC
Assessment u/s 153C - Since a response was on record, undoubtedly, the AO was required to issue a notice under Section 143(2) of the Act and then proceed further in the matter, and perhaps thereafter, frame an assessment u/s 147 read with Section 144 of the Act. This was not done. - for the AO to take recourse to Section 144 of the Act was completely uncalled. - HC
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