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 ...
An assessment based on undisclosed relied-upon material, including server data, corroborative search documents and an Investigation Wing screenshot, was held unsustainable because the assessee was never furnished those materials or given an opportunity to rebut them. The Tribunal held that this denial of access breached audi alteram partem and the broader requirements of natural justice, rendering the assessment arbitrary and bad in law. The assessment order was quashed on that ground alone, and the merits of the additions were left open as academic.
An assessment based on undisclosed relied-upon material, including server data, corroborative search documents and an Investigation Wing screenshot, was held unsustainable because the assessee was never furnished those materials or given an opportunity to rebut them. The Tribunal held that this denial of access breached audi alteram partem and the broader requirements of natural justice, rendering the assessment arbitrary and bad in law. The assessment order was quashed on that ground alone, and the merits of the additions were left open as academic.
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