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 ...
HC held that for calculating the 6-year limitation period under Section 153C(1), the relevant date is 30.06.2022, when documents were collected from the petitioner, not the search date of 10.11.2020. The show cause notice dated 30.12.2024 is within limitation. The petitioner retains the right to respond to the notice and contest proceedings. Despite a prior settlement, the Department retains liberty to pursue further action if new materials emerge. The writ petitions were consequently dismissed, finding no merit in the petitioner's limitation arguments.
HC held that for calculating the 6-year limitation period under Section 153C(1), the relevant date is 30.06.2022, when documents were collected from the petitioner, not the search date of 10.11.2020. The show cause notice dated 30.12.2024 is within limitation. The petitioner retains the right to respond to the notice and contest proceedings. Despite a prior settlement, the Department retains liberty to pursue further action if new materials emerge. The writ petitions were consequently dismissed, finding no merit in the petitioner's limitation arguments.
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