Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
A registered joint development agreement was treated as not effecting an immediate transfer for capital gains where no consideration was paid on execution and the assessee's right was only to a future 50% share in the constructed area. The arrangement was viewed as enabling the developer to obtain approvals, licences and finance, not as a transfer under part performance. On that basis, long-term capital gains were not taxable in the year of execution; the assessment was quashed, subject to verification of the year in which the share was actually offered to tax.
A registered joint development agreement was treated as not effecting an immediate transfer for capital gains where no consideration was paid on execution and the assessee's right was only to a future 50% share in the constructed area. The arrangement was viewed as enabling the developer to obtain approvals, licences and finance, not as a transfer under part performance. On that basis, long-term capital gains were not taxable in the year of execution; the assessment was quashed, subject to verification of the year in which the share was actually offered to tax.
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