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 - deduction claimed u/s 54 - In the ITR, the assessee clearly discloses the said sale consideration coupled with the deductions claimed as described above. Apparently, prior to issuance of notice u/s 148A(b) of the Act, the Assessing Officer failed to notice the said disclosures. - It is a clear case of non-application of mind by the AO - HC
Validity of Reopening of assessment - deduction claimed u/s 54 - In the ITR, the assessee clearly discloses the said sale consideration coupled with the deductions claimed as described above. Apparently, prior to issuance of notice u/s 148A(b) of the Act, the Assessing Officer failed to notice the said disclosures. - It is a clear case of non-application of mind by the AO - HC
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