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 ...
Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
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