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 ...
Rectification of mistake u/s 154 - period of limitation - the original assessment u/s 143(3) is dated 21.11.2011 - the order u/s 154 has been passed on 29.06.2017, which is clearly beyond the period of four years specified and therefore, the 154 order passed by the AO is beyond the period of the limitation provided. Accordingly, same is invalid in law and thus it is quashed. - AT
Rectification of mistake u/s 154 - period of limitation - the original assessment u/s 143(3) is dated 21.11.2011 - the order u/s 154 has been passed on 29.06.2017, which is clearly beyond the period of four years specified and therefore, the 154 order passed by the AO is beyond the period of the limitation provided. Accordingly, same is invalid in law and thus it is quashed. - AT
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