Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Redevelopment hardship compensation received as a predetermined lump-sum for shifting, re-shifting, demolition-related inconvenience and shared common areas was held to be a capital receipt, not consideration for transfer of property rights, so the addition was deleted. The first appellate authority's direction to compute capital gain on the additional 56% carpet area was treated as an enhancement of income; because no prior show-cause notice or opportunity under section 251(2) was shown, that enhancement was set aside and the issue was remitted for fresh consideration after hearing the assessee.
Redevelopment hardship compensation received as a predetermined lump-sum for shifting, re-shifting, demolition-related inconvenience and shared common areas was held to be a capital receipt, not consideration for transfer of property rights, so the addition was deleted. The first appellate authority's direction to compute capital gain on the additional 56% carpet area was treated as an enhancement of income; because no prior show-cause notice or opportunity under section 251(2) was shown, that enhancement was set aside and the issue was remitted for fresh consideration after hearing the assessee.
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