Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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The Tribunal held that the limitation challenge could be decided despite pendency before the Supreme Court because the assessees relied on an unstayed precedent. Reading sections 144C and 153 together, it rejected the Revenue's contention that limitation for a final assessment order under section 144C(13) must be tested only under section 144C. Applying the Roca Bathroom Products line of reasoning, it found the impugned final assessment orders for the relevant assessment years were passed beyond the permissible period and therefore barred by limitation. The orders were quashed, and the remaining grounds were left open.
The Tribunal held that the limitation challenge could be decided despite pendency before the Supreme Court because the assessees relied on an unstayed precedent. Reading sections 144C and 153 together, it rejected the Revenue's contention that limitation for a final assessment order under section 144C(13) must be tested only under section 144C. Applying the Roca Bathroom Products line of reasoning, it found the impugned final assessment orders for the relevant assessment years were passed beyond the permissible period and therefore barred by limitation. The orders were quashed, and the remaining grounds were left open.
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