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 assessment order u/s. 147 r.w.s 144 - Assessee being Non-Resident Indian - The AO assessed the property below its market value, leading to an addition of income from other sources. The appellant contested this assessment, alleging procedural lapses including the failure to consider evidence and the non-referral of the matter to the Valuation Officer. Additionally, objections raised before the DRP were not adequately addressed. The Tribunal remitted the matter back to the AO for de novo consideration, granting the appellant another opportunity to present their case.
Validity of assessment order u/s. 147 r.w.s 144 - Assessee being Non-Resident Indian - The AO assessed the property below its market value, leading to an addition of income from other sources. The appellant contested this assessment, alleging procedural lapses including the failure to consider evidence and the non-referral of the matter to the Valuation Officer. Additionally, objections raised before the DRP were not adequately addressed. The Tribunal remitted the matter back to the AO for de novo consideration, granting the appellant another opportunity to present their case.
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