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...
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Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
Assessment orders become effective only when signed, and dating an order within time does not satisfy the statutory limit if signature follows later. The HC held that for AY 2023-24, the limitation under section 153 expired on 31 March 2025, but the assessment order was digitally signed only on 25 December 2025. As the computation sheet and notice of demand were also signed after expiry of limitation, they were not validly made within time. Treating signature as an essential requirement of legal validity, the Court held the assessment order, computation sheet and notice of demand to be time-barred and quashed them.
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