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 ...
Reopening of assessment u/s 147 - Decision concerning leases was delivered in the year 2014. Till that time neither the assessee nor the Assessing Officer had knowledge that such leases were illegal after 22.11.2007. When assessee was not knowing, there was no occasion for him to make disclosure to that effect. - The reassessment notices under Section 148 of the Income Tax Act for the years 2008-09 and 2011-12 were quashed due to the failure of the Assessing Officer to meet the necessary legal conditions, including the lack of independent verification and inquiry, and the inapplicability of the additional conditions required for reassessment beyond four years. - HC
Reopening of assessment u/s 147 - Decision concerning leases was delivered in the year 2014. Till that time neither the assessee nor the Assessing Officer had knowledge that such leases were illegal after 22.11.2007. When assessee was not knowing, there was no occasion for him to make disclosure to that effect. - The reassessment notices under Section 148 of the Income Tax Act for the years 2008-09 and 2011-12 were quashed due to the failure of the Assessing Officer to meet the necessary legal conditions, including the lack of independent verification and inquiry, and the inapplicability of the additional conditions required for reassessment beyond four years. - HC
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