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 - period of limitation - Although the notice dated 30.06.2021 u/s 148 bears an endorsement at the foot of the page that it has been digitally signed, it is inchoate, in the sense that it is not accompanied by a date. - Admittedly, the said notice was never physically delivered to the assessee. As such, the fact remains that service of the said notice u/s 148 was affected on the petitioner only on 16.07.2021 through email, though the limitation period had already expired on 30.06.2021. - HC
Validity of Reopening of assessment - period of limitation - Although the notice dated 30.06.2021 u/s 148 bears an endorsement at the foot of the page that it has been digitally signed, it is inchoate, in the sense that it is not accompanied by a date. - Admittedly, the said notice was never physically delivered to the assessee. As such, the fact remains that service of the said notice u/s 148 was affected on the petitioner only on 16.07.2021 through email, though the limitation period had already expired on 30.06.2021. - HC
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