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...
Foreign tax credit should not be denied where Form No. 67 was available on or before the return-filing due date and the claim was supported by the return. Submission of the form, foreign tax deduction certificate, and material on the corresponding foreign income requires verification, since tax cannot be collected without authority of law; the credit claim was remanded for verification and consequential grant if allowable. Delay in electronically filing an appeal in Form No. 35 may be condoned where lack of awareness of the electronic process and available appellate remedy constitutes sufficient cause, particularly when the appeal is filed promptly after professional advice.
Foreign tax credit should not be denied where Form No. 67 was available on or before the return-filing due date and the claim was supported by the return. Submission of the form, foreign tax deduction certificate, and material on the corresponding foreign income requires verification, since tax cannot be collected without authority of law; the credit claim was remanded for verification and consequential grant if allowable. Delay in electronically filing an appeal in Form No. 35 may be condoned where lack of awareness of the electronic process and available appellate remedy constitutes sufficient cause, particularly when the appeal is filed promptly after professional advice.
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