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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Assessment made u/s 144 r.w.s. 142(1) OR 153C - The Tribunal held that the assessment made u/s 144 r.w.s. 142(1) for A.Y. 2012-13, based on the satisfaction recorded on 18.11.2013 (A.Y. 2014-15), should have been conducted u/s 153C of the Income Tax Act. The Tribunal referenced the judgments of the Hon’ble Delhi High Court and the Hon’ble Supreme Court, stating that the satisfaction note must explicitly indicate that the seized documents belong to the assessee. The Tribunal found that the assessments made were outside the scope of Section 153C, and hence, the assessment u/s 144 r.w.s. 142(1) was void ab initio.
Assessment made u/s 144 r.w.s. 142(1) OR 153C - The Tribunal held that the assessment made u/s 144 r.w.s. 142(1) for A.Y. 2012-13, based on the satisfaction recorded on 18.11.2013 (A.Y. 2014-15), should have been conducted u/s 153C of the Income Tax Act. The Tribunal referenced the judgments of the Hon’ble Delhi High Court and the Hon’ble Supreme Court, stating that the satisfaction note must explicitly indicate that the seized documents belong to the assessee. The Tribunal found that the assessments made were outside the scope of Section 153C, and hence, the assessment u/s 144 r.w.s. 142(1) was void ab initio.
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