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...
HC held that for reassessment proceedings under Section 153C, the relevant date is when the Assessing Officer decides to initiate re-assessment, not the search date. The ten-year block is calculated from the end of AY 2024-25, when the notice was issued on 30.03.2024. Consistent with prior judicial precedents, the court found the impugned notice barred by limitation and allowed the petition, setting aside the notice as time-barred.
HC held that for reassessment proceedings under Section 153C, the relevant date is when the Assessing Officer decides to initiate re-assessment, not the search date. The ten-year block is calculated from the end of AY 2024-25, when the notice was issued on 30.03.2024. Consistent with prior judicial precedents, the court found the impugned notice barred by limitation and allowed the petition, setting aside the notice as time-barred.
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