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 - entitlement to exemption u/s 54F - The High Court examines Section 54F of the Act and concludes that the reassessment is based on a mere change of opinion, as the same facts were considered in previous assessments without disallowing the exemption under Section 54F.- Referring to the decision in Calcutta Discount Company Ltd. vs. Income Tax Officer, the Court holds that the petitioner is entitled to relief under Article 226 of the Constitution due to lack of jurisdiction by the Assessing Officer.
Validity of Reopening of assessment u/s 147 - entitlement to exemption u/s 54F - The High Court examines Section 54F of the Act and concludes that the reassessment is based on a mere change of opinion, as the same facts were considered in previous assessments without disallowing the exemption under Section 54F.- Referring to the decision in Calcutta Discount Company Ltd. vs. Income Tax Officer, the Court holds that the petitioner is entitled to relief under Article 226 of the Constitution due to lack of jurisdiction by the Assessing Officer.
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