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 - shorter period to reply to notice - The High Court acknowledged the petitioner's argument regarding the limited time provided for response. Considering the petitioner's status as a Public Trust running a school, the Court deemed it appropriate to grant an opportunity for a reply to the notice. - The Court, without expressing an opinion on the merits, quashed the impugned order and remanded the matter for fresh consideration.
Validity of reopening of assessment u/s 147 - shorter period to reply to notice - The High Court acknowledged the petitioner's argument regarding the limited time provided for response. Considering the petitioner's status as a Public Trust running a school, the Court deemed it appropriate to grant an opportunity for a reply to the notice. - The Court, without expressing an opinion on the merits, quashed the impugned order and remanded the matter for fresh consideration.
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