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 - Reasons to believe - The court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the proforma maintained by the respondent. It noted minor differences in language but found that the substance of the reasons remained consistent. The court emphasized that the material basis for initiating re-assessment was the same in both documents, and minor variations in language did not warrant interference with the proceedings. - The writ petition was dismissed, upholding the validity of the notices issued for re-assessment.
Reopening of assessment u/s 147 - Reasons to believe - The court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the proforma maintained by the respondent. It noted minor differences in language but found that the substance of the reasons remained consistent. The court emphasized that the material basis for initiating re-assessment was the same in both documents, and minor variations in language did not warrant interference with the proceedings. - The writ petition was dismissed, upholding the validity of the notices issued for re-assessment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
