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 key points from the legal text are: Section 153A assessment - Limitation period applies based on when seized materials were handed over to the Assessing Officer (AO), not the search date. Despite 60-day limit in Section 132(9A) for handing over seized assets, non-adherence does not invalidate assessment if within extended limitation u/s 153B(1) proviso. Validity of satisfaction notes u/s 153C - Separate notes recorded for each year, concluding seized materials pertained to assessee and impacted income. Satisfied threshold u/s 153C(1) despite not explicitly mentioning all earlier years. Transfer order u/s 127 - Mixed questions of fact and law involved in determining if consent/consultation requirements were met. No findings recorded due to lack of pleadings. Addition u/s 69 read with 115BBE - Applicable for unexplained investments not recorded in books, even if no books maintained. Computation of income and tax liability upheld.
The key points from the legal text are: Section 153A assessment - Limitation period applies based on when seized materials were handed over to the Assessing Officer (AO), not the search date. Despite 60-day limit in Section 132(9A) for handing over seized assets, non-adherence does not invalidate assessment if within extended limitation u/s 153B(1) proviso. Validity of satisfaction notes u/s 153C - Separate notes recorded for each year, concluding seized materials pertained to assessee and impacted income. Satisfied threshold u/s 153C(1) despite not explicitly mentioning all earlier years. Transfer order u/s 127 - Mixed questions of fact and law involved in determining if consent/consultation requirements were met. No findings recorded due to lack of pleadings. Addition u/s 69 read with 115BBE - Applicable for unexplained investments not recorded in books, even if no books maintained. Computation of income and tax liability upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
