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 ...
Validity of Reopening of assessment - reason to belief - Bogus share transactions - AO, while recording the reasons, has not applied his mind and has not brought out any factual finding with regard to the impugned addition. It is also noticed that the assessee’s request with regard to the workings of the impugned addition and the statements recorded from the Broker was not shared with him by the lower authorities - the reopening u/s. 147 is not valid and accordingly, the addition made stands deleted. - AT
Validity of Reopening of assessment - reason to belief - Bogus share transactions - AO, while recording the reasons, has not applied his mind and has not brought out any factual finding with regard to the impugned addition. It is also noticed that the assessee’s request with regard to the workings of the impugned addition and the statements recorded from the Broker was not shared with him by the lower authorities - the reopening u/s. 147 is not valid and accordingly, the addition made stands deleted. - AT
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