Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
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Appellate proceedings cannot be used to introduce a new head of income or enhance an assessment without following the prescribed procedure. Where the original dispute concerned only denial of deduction under section 54F on the basis of alleged multiple residential units and a claimed sham transfer, and the appellate authority accepted that the transfer was lawful, that controversy stood concluded. The further step of taxing the share-sale consideration under section 56 amounted to an unauthorised enhancement and a change in the basis of assessment. The appellate order was therefore unsustainable, and the deduction under section 54F was directed to be allowed.
Appellate proceedings cannot be used to introduce a new head of income or enhance an assessment without following the prescribed procedure. Where the original dispute concerned only denial of deduction under section 54F on the basis of alleged multiple residential units and a claimed sham transfer, and the appellate authority accepted that the transfer was lawful, that controversy stood concluded. The further step of taxing the share-sale consideration under section 56 amounted to an unauthorised enhancement and a change in the basis of assessment. The appellate order was therefore unsustainable, and the deduction under section 54F was directed to be allowed.
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