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 High Court addressed the validity of an assessment u/s 153A and the jurisdiction for assessment proceedings transfer. The petitioner challenged the transfer from Sangli to Kozhikode, citing lack of mandatory notice and hearing u/s 127(2) and absence of a Document Identification Number (DIN) in the order. The Court found that notice was duly served, giving the petitioner an opportunity to respond, which was not utilized. The absence of DIN is being considered by the Supreme Court, but the transfer was deemed valid as the petitioner's business and recovery were within Kozhikode's jurisdiction. The Court dismissed the writ petition, finding no errors in the proceedings.
The High Court addressed the validity of an assessment u/s 153A and the jurisdiction for assessment proceedings transfer. The petitioner challenged the transfer from Sangli to Kozhikode, citing lack of mandatory notice and hearing u/s 127(2) and absence of a Document Identification Number (DIN) in the order. The Court found that notice was duly served, giving the petitioner an opportunity to respond, which was not utilized. The absence of DIN is being considered by the Supreme Court, but the transfer was deemed valid as the petitioner's business and recovery were within Kozhikode's jurisdiction. The Court dismissed the writ petition, finding no errors in the proceedings.
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