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 ...
Conduct of Reassessment Proceedings - Principles of Natural Justice - The High court found that the reassessment proceedings were conducted in great haste, violating the principles of natural justice. The Additional Commissioner granted permission to the Assessing Officer on 18.3.2023, and the notice was issued on 22.3.2023, served on the petitioner on 24.3.2023, with the reassessment order passed on 28.3.2023. The court noted that the petitioner was not given a reasonable opportunity to respond, as only two days were provided to respond to the reassessment notice. The court held that such a procedure undermined the trust in the rule of law and was unacceptable.
Conduct of Reassessment Proceedings - Principles of Natural Justice - The High court found that the reassessment proceedings were conducted in great haste, violating the principles of natural justice. The Additional Commissioner granted permission to the Assessing Officer on 18.3.2023, and the notice was issued on 22.3.2023, served on the petitioner on 24.3.2023, with the reassessment order passed on 28.3.2023. The court noted that the petitioner was not given a reasonable opportunity to respond, as only two days were provided to respond to the reassessment notice. The court held that such a procedure undermined the trust in the rule of law and was unacceptable.
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