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 issue of reopening assessment u/s 147 of the Income Tax Act. The case involved the alleged absence of a "reason to believe" and a "live link" between information and belief. The assessment was reopened based on information uploaded by the ADIT (Inv) on the Income Tax Department's portal, designated as "High Risk Transaction" for 2016-17. The petitioner had declared the loss in the return for 2017-18, which was accepted by the AO. The Court emphasized that reopening required a valid reason to believe income had escaped assessment, not merely a change of opinion. The Court found the existing Section 147 requirements were not met, as no credible information supported the reopening. The notice u/s 148 and the subsequent order were quashed in favor of the assessee.
The High Court addressed the issue of reopening assessment u/s 147 of the Income Tax Act. The case involved the alleged absence of a "reason to believe" and a "live link" between information and belief. The assessment was reopened based on information uploaded by the ADIT (Inv) on the Income Tax Department's portal, designated as "High Risk Transaction" for 2016-17. The petitioner had declared the loss in the return for 2017-18, which was accepted by the AO. The Court emphasized that reopening required a valid reason to believe income had escaped assessment, not merely a change of opinion. The Court found the existing Section 147 requirements were not met, as no credible information supported the reopening. The notice u/s 148 and the subsequent order were quashed in favor of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
