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...
TDS credit under section 199 must follow the person who has offered the corresponding income to tax. Where a proprietorship is converted into a partnership firm but clients continue deducting tax under the former proprietor's PAN, the individual proprietor cannot claim credit if the related income was returned by the firm. The firm may seek the credit through rectification for the relevant years, subject to verification that it offered the income and that the credit is otherwise admissible. The material describes denial of credit to the individual while permitting the firm to pursue the corresponding credit.
TDS credit under section 199 must follow the person who has offered the corresponding income to tax. Where a proprietorship is converted into a partnership firm but clients continue deducting tax under the former proprietor's PAN, the individual proprietor cannot claim credit if the related income was returned by the firm. The firm may seek the credit through rectification for the relevant years, subject to verification that it offered the income and that the credit is otherwise admissible. The material describes denial of credit to the individual while permitting the firm to pursue the corresponding credit.
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