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...
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A one-day delay in uploading Form 10DA for the additional employment deduction was treated as a procedural lapse, not a substantive defect, because the form was already on record before the section 143(1) intimation. The Tribunal followed co-ordinate Bench rulings that the prescribed form is a compliance requirement for verification, and the claim cannot be denied once the form is available before assessment or intimation. Reliance on Wipro was distinguished as an exemption-case authority, not a deduction-case authority. The disallowance was deleted and the deduction allowed.
A one-day delay in uploading Form 10DA for the additional employment deduction was treated as a procedural lapse, not a substantive defect, because the form was already on record before the section 143(1) intimation. The Tribunal followed co-ordinate Bench rulings that the prescribed form is a compliance requirement for verification, and the claim cannot be denied once the form is available before assessment or intimation. Reliance on Wipro was distinguished as an exemption-case authority, not a deduction-case authority. The disallowance was deleted and the deduction allowed.
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