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 ...
The ITAT Chandigarh considered a revision u/s 263 by CIT regarding the period of limitation for completing requisite action. The assessment order was passed on 18/02/2014, and any issues requiring revision should have been addressed by 31/03/2016, within two years from the end of the relevant financial year. The revisionary order was found valid for transfer expenses, CLU charges, and deduction u/s 54F arising from reassessment. However, the revisionary proceedings related to the sale of land in District Solan were deemed barred by limitation as they pertained to the original assessment, not the reassessment. The availability of documentary evidence for transfer expenses and CLU charges was confirmed, and the AO's decision was upheld as not prejudicial to revenue. The deduction u/s 54F was restricted to Rs. 30,49,998 as determined by the Ld. Pr. CIT. The Assessee's appeal was partly allowed.
The ITAT Chandigarh considered a revision u/s 263 by CIT regarding the period of limitation for completing requisite action. The assessment order was passed on 18/02/2014, and any issues requiring revision should have been addressed by 31/03/2016, within two years from the end of the relevant financial year. The revisionary order was found valid for transfer expenses, CLU charges, and deduction u/s 54F arising from reassessment. However, the revisionary proceedings related to the sale of land in District Solan were deemed barred by limitation as they pertained to the original assessment, not the reassessment. The availability of documentary evidence for transfer expenses and CLU charges was confirmed, and the AO's decision was upheld as not prejudicial to revenue. The deduction u/s 54F was restricted to Rs. 30,49,998 as determined by the Ld. Pr. CIT. The Assessee's appeal was partly allowed.
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