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 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with the petitioner, highlighting the casual manner in which approvals were granted, without proper verification or consideration of the material on record. Emphasizing the importance of exercising the power to reopen assessments with due diligence, the High Court quashed the impugned order and the consequent notice.
Validity of Reopening of assessment u/s 147 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with the petitioner, highlighting the casual manner in which approvals were granted, without proper verification or consideration of the material on record. Emphasizing the importance of exercising the power to reopen assessments with due diligence, the High Court quashed the impugned order and the consequent notice.
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