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...
An AO must pass the final assessment order in conformity with the DRP's directions under section 144C(13); any departure, even if said to be due to mistake or misunderstanding, is impermissible. Applying binding High Court precedent, the Tribunal quashed the non-compliant final assessment order because the AO repeated the draft order and ignored the relief granted by the DRP. The transfer pricing and consequential grounds were left open as academic.
An AO must pass the final assessment order in conformity with the DRP's directions under section 144C(13); any departure, even if said to be due to mistake or misunderstanding, is impermissible. Applying binding High Court precedent, the Tribunal quashed the non-compliant final assessment order because the AO repeated the draft order and ignored the relief granted by the DRP. The transfer pricing and consequential grounds were left open as academic.
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