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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Validity of reopening of assessment - period of limitation to issue notice - validity of a notice issued under Section 148/148A - scope of Taxation and other laws (Relaxation and Amendment of certain provisions) Act, 2020 (TOLA) application - The High Court refers to a previous judgment and concludes that the notices issued for the Assessment Year 2013-2014 are barred by limitation due to the amendments to the Finance Act and the provisions existing prior to the amendment. - The Court specifically addresses various contentions raised by the Department regarding the applicability of different legal provisions and notifications, ultimately ruling in favor of the petitioners.
Validity of reopening of assessment - period of limitation to issue notice - validity of a notice issued under Section 148/148A - scope of Taxation and other laws (Relaxation and Amendment of certain provisions) Act, 2020 (TOLA) application - The High Court refers to a previous judgment and concludes that the notices issued for the Assessment Year 2013-2014 are barred by limitation due to the amendments to the Finance Act and the provisions existing prior to the amendment. - The Court specifically addresses various contentions raised by the Department regarding the applicability of different legal provisions and notifications, ultimately ruling in favor of the petitioners.
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