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...
GST liability on works executed under pre-GST contracts remains governed exclusively by the applicable GST enactments and cannot be altered by contractual terms or an employer's failure to reimburse differential tax. A contractor's claim for incremental GST reimbursement is confined to the contractual relationship with the concerned employer and does not bind tax authorities. Revised returns, waiver of interest or penalties, and relaxation of statutory limitation cannot be granted through directions arising from a contractual reimbursement dispute, as these matters remain subject to the GST statutory framework. Directions affecting tax authorities or the State beyond that framework were treated as unsustainable.
GST liability on works executed under pre-GST contracts remains governed exclusively by the applicable GST enactments and cannot be altered by contractual terms or an employer's failure to reimburse differential tax. A contractor's claim for incremental GST reimbursement is confined to the contractual relationship with the concerned employer and does not bind tax authorities. Revised returns, waiver of interest or penalties, and relaxation of statutory limitation cannot be granted through directions arising from a contractual reimbursement dispute, as these matters remain subject to the GST statutory framework. Directions affecting tax authorities or the State beyond that framework were treated as unsustainable.
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