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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 - The High Court found that the Assessing Officer issued the notice based on the survey action on Jammu & Kashmir Bank, conducted after the original assessment order. The Court concluded that the notice was not issued due to any fresh tangible material but rather on the basis of the same material already available during the original assessment proceedings. The Court noted that the discrepancies in remittance amounts were explained by the bank's practice of applying notional and actual rates during transaction processing. The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961.
Validity of reopening of assessment - The High Court found that the Assessing Officer issued the notice based on the survey action on Jammu & Kashmir Bank, conducted after the original assessment order. The Court concluded that the notice was not issued due to any fresh tangible material but rather on the basis of the same material already available during the original assessment proceedings. The Court noted that the discrepancies in remittance amounts were explained by the bank's practice of applying notional and actual rates during transaction processing. The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961.
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