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 assessment order passed u/s 144C - period of limitation - The ITAT Delhi found the final assessment order dated 30.06.2022 to be barred by limitation. It was established that the directions from the DRP were uploaded to the ITBA portal on 07.04.2022, contrary to the claim of the AO that they were made known only on 02.05.2022. Accordingly, the AO was required to pass the final assessment order by 31.05.2022, making the actual order passed on 30.06.2022 out of time.
Validity of assessment order passed u/s 144C - period of limitation - The ITAT Delhi found the final assessment order dated 30.06.2022 to be barred by limitation. It was established that the directions from the DRP were uploaded to the ITBA portal on 07.04.2022, contrary to the claim of the AO that they were made known only on 02.05.2022. Accordingly, the AO was required to pass the final assessment order by 31.05.2022, making the actual order passed on 30.06.2022 out of time.
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