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 u/s 147 - order passed u/s 148A(d) - reason to believe - The High Court observed that, the assessing officer would state that no prudent businessman will simply withdraw crores of cash from his bank account and again will deposit it at various stage. This is a personal opinion of the assessing officer. However, for the purpose of reopening an assessment there should be a tangible material placed by the assessing officer to show that there was escapement of income from the payment of income tax. - The HC allowed the appeal and the order passed u/s 148A(d) and the consequential notice u/s 148 of the Act are quashed
Validity of reopening of assessment u/s 147 - order passed u/s 148A(d) - reason to believe - The High Court observed that, the assessing officer would state that no prudent businessman will simply withdraw crores of cash from his bank account and again will deposit it at various stage. This is a personal opinion of the assessing officer. However, for the purpose of reopening an assessment there should be a tangible material placed by the assessing officer to show that there was escapement of income from the payment of income tax. - The HC allowed the appeal and the order passed u/s 148A(d) and the consequential notice u/s 148 of the Act are quashed
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