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 ...
Processing of invalid return u/s 143(1) - Denial of exemption u/s 10(23C)(iiiad) - non-filing of ITR-V within 120 days made the assessee’s return as ‘invalid’ being deemed to have been never filed which was picked for processing - Assessee filed 2nd belated return u/s 139(4) - The ITAT held that, since the initial return was invalid, the intimation issued by the CPC based on it was also invalid. The CPC should have considered the second valid return available in the departmental database at the time of processing under section 143(1).
Processing of invalid return u/s 143(1) - Denial of exemption u/s 10(23C)(iiiad) - non-filing of ITR-V within 120 days made the assessee’s return as ‘invalid’ being deemed to have been never filed which was picked for processing - Assessee filed 2nd belated return u/s 139(4) - The ITAT held that, since the initial return was invalid, the intimation issued by the CPC based on it was also invalid. The CPC should have considered the second valid return available in the departmental database at the time of processing under section 143(1).
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