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 ...
Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
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