https://www.taxtmi.com/caselaws?id=342687 A development arrangement may trigger deemed transfer under section 2(47)(v) where the developer is given effective possession and control and the ingredients of section 53A of the Transfer of Property Act are satisfied, even if legal title is not formally conveyed. Reopening under sections 147 and 148 is supported where the original return was only processed under section 143(1) and the Assessing Officer records tangible material suggesting escapement of income. Capital-gains quantification may require fresh factual verification where the consideration adopted is not properly supported. Sponsorship expenditure was treated as non-business in nature, while the section 14A disallowance did not survive because it was not pressed. en-us Mon, 08 May 2017 00:00:00 +0530 Wed, 10 May 2017 07:23:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=342687 A development arrangement may trigger deemed transfer under section 2(47)(v) where the developer is given effective possession and control and the ingredients of section 53A of the Transfer of Property Act are satisfied, even if legal title is not formally conveyed. Reopening under sections 147 and 148 is supported where the original return was only processed under section 143(1) and the Assessing Officer records tangible material suggesting escapement of income. Capital-gains quantification may require fresh factual verification where the consideration adopted is not properly supported. Sponsorship expenditure was treated as non-business in nature, while the section 14A disallowance did not survive because it was not pressed. Case-Laws Income Tax Mon, 08 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=342687