Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Under the amended reassessment regime, the High Court held that capital gains from the property transfer had to be computed with the stamp duty valuation under Sections 148, 149, 50C and 48. Because the petitioner's one-fourth share, valued on that basis, exceeded the statutory threshold of fifty lakh rupees, the extended limitation period applied and the Section 148A(d) order and consequential Section 148 notice were not without jurisdiction. The Court also held that the complaint that the written reply was not considered did not alter the result once limitation was decided against the petitioner. The writ petition was dismissed and assessment was directed to proceed, excluding the period spent before the Court for limitation purposes.
Under the amended reassessment regime, the High Court held that capital gains from the property transfer had to be computed with the stamp duty valuation under Sections 148, 149, 50C and 48. Because the petitioner's one-fourth share, valued on that basis, exceeded the statutory threshold of fifty lakh rupees, the extended limitation period applied and the Section 148A(d) order and consequential Section 148 notice were not without jurisdiction. The Court also held that the complaint that the written reply was not considered did not alter the result once limitation was decided against the petitioner. The writ petition was dismissed and assessment was directed to proceed, excluding the period spent before the Court for limitation purposes.
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