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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Section 148A(b) requires at least seven days to respond; a notice granting only five days was held contrary to statute, and the assessee's later extension request did not cure the defect. The resulting order under section 148A(d) and reassessment were therefore unsustainable. The notice under section 148 was also time-barred, as the limitation for A.Y. 2015-16 expired on 31/03/2022 but the notice was issued on 04/04/2022. On merits, the addition for unexplained investment could not be made wholly in the assessee's hands because the sale deed showed joint ownership of the property with his wife.
Section 148A(b) requires at least seven days to respond; a notice granting only five days was held contrary to statute, and the assessee's later extension request did not cure the defect. The resulting order under section 148A(d) and reassessment were therefore unsustainable. The notice under section 148 was also time-barred, as the limitation for A.Y. 2015-16 expired on 31/03/2022 but the notice was issued on 04/04/2022. On merits, the addition for unexplained investment could not be made wholly in the assessee's hands because the sale deed showed joint ownership of the property with his wife.
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