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 ruling on tax reassessment for AY 2014-2015: The court held that the reassessment notice under Section 148 was invalid. The AO's reopening of assessment was deemed a mere change of opinion rather than discovery of new material, as the original assessment was based on search operation materials. The court found that the materials used for reopening were already part of the original assessment proceedings. Consequently, the court set aside the reassessment notice dated 31.03.2021 and the order rejecting objections dated 21.02.2022, effectively allowing the writ petition and invalidating the reassessment proceedings.
HC ruling on tax reassessment for AY 2014-2015: The court held that the reassessment notice under Section 148 was invalid. The AO's reopening of assessment was deemed a mere change of opinion rather than discovery of new material, as the original assessment was based on search operation materials. The court found that the materials used for reopening were already part of the original assessment proceedings. Consequently, the court set aside the reassessment notice dated 31.03.2021 and the order rejecting objections dated 21.02.2022, effectively allowing the writ petition and invalidating the reassessment proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
