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 - An order u/s 245D(4) already been passed by the Income Tax Settlement Commission (ITSC) - Scope of harmonious construction - The Delhi High Court, in this judgment, reinforced the binding and conclusive nature of orders passed by the Income Tax Settlement Commission, underscoring that once an assessment year's matters have been settled by ITSC, they cannot be reopened by the Income Tax Department under Section 147/148, except under specific circumstances of fraud or misrepresentation. This decision highlights the judiciary's commitment to uphold the finality and sanctity of ITSC's settlements, aiming to prevent administrative uncertainty and protect the interests of assessees who opt for settlement proceedings.
Validity of reopening of assessment - An order u/s 245D(4) already been passed by the Income Tax Settlement Commission (ITSC) - Scope of harmonious construction - The Delhi High Court, in this judgment, reinforced the binding and conclusive nature of orders passed by the Income Tax Settlement Commission, underscoring that once an assessment year's matters have been settled by ITSC, they cannot be reopened by the Income Tax Department under Section 147/148, except under specific circumstances of fraud or misrepresentation. This decision highlights the judiciary's commitment to uphold the finality and sanctity of ITSC's settlements, aiming to prevent administrative uncertainty and protect the interests of assessees who opt for settlement proceedings.
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