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...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
ITAT upheld the reassessment notice because the record showed prior approval of the Principal Commissioner on the notice under section 148A(b), and both the notice and approval were within the statutory time limit, so the challenge on limitation and lack of approval failed. On disputed bogus purchases, the Tribunal held that invoices, ledgers and banking entries were not enough where Investigation Wing and GST material indicated accommodation entry suppliers and there were deficiencies in transport and purchase-to-sale linkage. It found that the existing factual examination was inadequate to sustain either full disallowance or a restriction to 15%, and restored the matter to the Assessing Officer for fresh verification and enquiries.
ITAT upheld the reassessment notice because the record showed prior approval of the Principal Commissioner on the notice under section 148A(b), and both the notice and approval were within the statutory time limit, so the challenge on limitation and lack of approval failed. On disputed bogus purchases, the Tribunal held that invoices, ledgers and banking entries were not enough where Investigation Wing and GST material indicated accommodation entry suppliers and there were deficiencies in transport and purchase-to-sale linkage. It found that the existing factual examination was inadequate to sustain either full disallowance or a restriction to 15%, and restored the matter to the Assessing Officer for fresh verification and enquiries.
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