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...
Eligibility to act as an authorised representative is distinct from eligibility for registration as an Income Tax Practitioner. Section 515 read with Rule 252 governs who may appear as an authorised representative, while Rules 255 to 257 govern entry in the register and grant of a certificate of registration. The one-year practice requirement in Rule 257 applies only to registration; it does not restrict the separate right to appear as a representative. As the applicant had not completed one year's practice on the date of application, and the rule itself was not challenged, the return of the application was held lawful and a fresh application was permitted after completion of the prescribed period.
Eligibility to act as an authorised representative is distinct from eligibility for registration as an Income Tax Practitioner. Section 515 read with Rule 252 governs who may appear as an authorised representative, while Rules 255 to 257 govern entry in the register and grant of a certificate of registration. The one-year practice requirement in Rule 257 applies only to registration; it does not restrict the separate right to appear as a representative. As the applicant had not completed one year's practice on the date of application, and the rule itself was not challenged, the return of the application was held lawful and a fresh application was permitted after completion of the prescribed period.
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