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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Payments of accumulated charitable income to another registered institution were treated as taxable under the deeming rule because the source of funds was accumulation and the recipient held charitable registration; the nomenclature of the transfer as project expenditure or implementation charges did not matter. The rectification under mistake apparent from record was upheld because the relevant facts were already on the assessment record and no fresh inquiry was needed, so the issue was not a debatable one or a review. A challenge based on denial of a video conference hearing in faceless appellate proceedings also failed for want of shown prejudice. Consequential interest was held mandatory and subject only to recomputation.
Payments of accumulated charitable income to another registered institution were treated as taxable under the deeming rule because the source of funds was accumulation and the recipient held charitable registration; the nomenclature of the transfer as project expenditure or implementation charges did not matter. The rectification under mistake apparent from record was upheld because the relevant facts were already on the assessment record and no fresh inquiry was needed, so the issue was not a debatable one or a review. A challenge based on denial of a video conference hearing in faceless appellate proceedings also failed for want of shown prejudice. Consequential interest was held mandatory and subject only to recomputation.
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