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...
Section 271C was noted as having been interpreted by the SC as inapplicable where tax deducted at source was deducted and remitted belatedly, supporting a prima facie challenge to penalty while leaving its final applicability for statutory appeals. The discussion states that circulars and office memoranda on stay of demand are guidelines, not statutory constraints on discretion under Section 220(6). Recovery of penalty was conditionally stayed pending appeal and for a further limited period, with expedited appellate disposal directed.
Section 271C was noted as having been interpreted by the SC as inapplicable where tax deducted at source was deducted and remitted belatedly, supporting a prima facie challenge to penalty while leaving its final applicability for statutory appeals. The discussion states that circulars and office memoranda on stay of demand are guidelines, not statutory constraints on discretion under Section 220(6). Recovery of penalty was conditionally stayed pending appeal and for a further limited period, with expedited appellate disposal directed.
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