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...
Electronic filing delay in Form 10B may constitute genuine hardship where the audit report and Form 10 were obtained before the return was filed but were not uploaded due to an inadvertent clerical omission connected with the trust's Chartered Accountant. The notes state that the applicable CBDT circular covered the relevant assessment year and that an earlier decision involving the same trust required a non-pedantic approach to technical compliance. The rejection of condonation was quashed, requiring condonation of the delay and enabling consideration of the charitable-income exemption claim.
Electronic filing delay in Form 10B may constitute genuine hardship where the audit report and Form 10 were obtained before the return was filed but were not uploaded due to an inadvertent clerical omission connected with the trust's Chartered Accountant. The notes state that the applicable CBDT circular covered the relevant assessment year and that an earlier decision involving the same trust required a non-pedantic approach to technical compliance. The rejection of condonation was quashed, requiring condonation of the delay and enabling consideration of the charitable-income exemption claim.
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