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 HC held that the AO did not independently verify the material on record or form an opinion that income escaped assessment due to the assessee's failure to disclose facts. The reopening was based on borrowed satisfaction from information received without independent application of mind. Merely relying on information from other sources without forming an independent opinion is impermissible for reassessment proceedings. The HC decided in favour of the assessee.
The HC held that the AO did not independently verify the material on record or form an opinion that income escaped assessment due to the assessee's failure to disclose facts. The reopening was based on borrowed satisfaction from information received without independent application of mind. Merely relying on information from other sources without forming an independent opinion is impermissible for reassessment proceedings. The HC decided in favour of the assessee.
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