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 - change of opinion - mechanical satisfaction - Admission of additional income by Senior Executive of the petitioner during the search - variation in additional income admitted - The High Court upheld the justification for reopening provided by the respondents, highlighting the availability of fresh material and alleged failures by the petitioners to fully disclose material evidence. Objections regarding change of opinion and mechanical satisfaction were rejected.
Reopening of assessment u/s 147 - change of opinion - mechanical satisfaction - Admission of additional income by Senior Executive of the petitioner during the search - variation in additional income admitted - The High Court upheld the justification for reopening provided by the respondents, highlighting the availability of fresh material and alleged failures by the petitioners to fully disclose material evidence. Objections regarding change of opinion and mechanical satisfaction were rejected.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
