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 ...
Validity of faceless assessment challenged due to non-compliance with Section 151A - notices issued by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO). High Court held that JAO lacked jurisdiction to issue notices u/s 148, particularly in view of Section 151A read with Central Government notification dated 29 March 2022. Relying on Hexaware Technologies Ltd. case, the Court ruled the impugned notices illegal and invalid as JAO had no jurisdiction. Petition allowed in favor of assessee.
Validity of faceless assessment challenged due to non-compliance with Section 151A - notices issued by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO). High Court held that JAO lacked jurisdiction to issue notices u/s 148, particularly in view of Section 151A read with Central Government notification dated 29 March 2022. Relying on Hexaware Technologies Ltd. case, the Court ruled the impugned notices illegal and invalid as JAO had no jurisdiction. Petition allowed in favor of assessee.
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