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...
Delay in filing Form 10-IC for the concessional corporate tax regime may be condoned where the return was filed on time, the option was disclosed in the return, tax was paid at the concessional rate, and the omission was a bona fide lapse. The HC treated the delay as a case of genuine hardship, noting that the relevant circulars showed an intent to grant relief in fit cases, including the period affected by COVID-19 and the initial years of the regime. It held that the authority should have taken a justice-oriented approach rather than reject condonation on the basis that a tax manager's or consultant's lapse could never justify relief. The rejection and consequential denial of the benefit were set aside.
Delay in filing Form 10-IC for the concessional corporate tax regime may be condoned where the return was filed on time, the option was disclosed in the return, tax was paid at the concessional rate, and the omission was a bona fide lapse. The HC treated the delay as a case of genuine hardship, noting that the relevant circulars showed an intent to grant relief in fit cases, including the period affected by COVID-19 and the initial years of the regime. It held that the authority should have taken a justice-oriented approach rather than reject condonation on the basis that a tax manager's or consultant's lapse could never justify relief. The rejection and consequential denial of the benefit were set aside.
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