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...
Tax deduction on transfer of agricultural land under section 194-IA does not arise unless the land falls within that provision's scope. The text states that a registered sale deed identified the property as agricultural land and no contrary material established that it was covered land; therefore, no primary TDS obligation applied. Section 206AA only increases the deduction rate where tax is otherwise deductible and PAN is not furnished; it cannot independently create a TDS liability. Consequently, section 201(1) cannot treat the purchaser as an assessee in default absent a statutory duty to deduct. The short-deduction demand and consequential interest were deleted.
Tax deduction on transfer of agricultural land under section 194-IA does not arise unless the land falls within that provision's scope. The text states that a registered sale deed identified the property as agricultural land and no contrary material established that it was covered land; therefore, no primary TDS obligation applied. Section 206AA only increases the deduction rate where tax is otherwise deductible and PAN is not furnished; it cannot independently create a TDS liability. Consequently, section 201(1) cannot treat the purchaser as an assessee in default absent a statutory duty to deduct. The short-deduction demand and consequential interest were deleted.
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