Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Receipts claimed as advances for sale of land were taxed as income from other sources because the assessee could not establish ownership, possession, or any surviving contingent right in the land, and the factual basis for treating the sums as capital receipts failed. The Tribunal held that, absent any proved property right or transfer, the amounts were taxable in the hands of the assessee. It also sustained reopening under section 147 for A.Y. 2009-10, holding that an error in the recorded quantum of receipt did not undermine the underlying reason to believe, since the MOU, the deal value, and the receipt itself remained undisputed.
Receipts claimed as advances for sale of land were taxed as income from other sources because the assessee could not establish ownership, possession, or any surviving contingent right in the land, and the factual basis for treating the sums as capital receipts failed. The Tribunal held that, absent any proved property right or transfer, the amounts were taxable in the hands of the assessee. It also sustained reopening under section 147 for A.Y. 2009-10, holding that an error in the recorded quantum of receipt did not undermine the underlying reason to believe, since the MOU, the deal value, and the receipt itself remained undisputed.
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