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 the assessment reopening under SS147 was procedurally flawed. The AO failed to substantiate allegations of income escape by thoroughly examining disputed shipping bill evidence. The Assessee's contention of manual bill correction and non-involvement in alleged exports was not adequately addressed. Consequently, the SS148A(d) order was set aside, effectively nullifying the assessment reopening and upholding the Assessee's appeal without prejudice to potential future reassessment if concrete evidence emerges.
HC held that the assessment reopening under SS147 was procedurally flawed. The AO failed to substantiate allegations of income escape by thoroughly examining disputed shipping bill evidence. The Assessee's contention of manual bill correction and non-involvement in alleged exports was not adequately addressed. Consequently, the SS148A(d) order was set aside, effectively nullifying the assessment reopening and upholding the Assessee's appeal without prejudice to potential future reassessment if concrete evidence emerges.
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