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 ...
Dispute Resolution Panel directions bind the Assessing Officer when an eligible assessee files timely objections to a draft assessment order. A bona fide failure to separately intimate the Assessing Officer of those objections, where it causes no advantage or prejudice, does not justify ignoring the Panel's directions. Where the transfer-pricing order forming the sole basis of the final assessment has been revised pursuant to those directions, an assessment based on the superseded order is unsustainable. The final assessment, consequential demand and penalty-initiation notices were set aside, and the assessment was restored for fresh completion in conformity with the Panel's directions and revised transfer-pricing order.
Dispute Resolution Panel directions bind the Assessing Officer when an eligible assessee files timely objections to a draft assessment order. A bona fide failure to separately intimate the Assessing Officer of those objections, where it causes no advantage or prejudice, does not justify ignoring the Panel's directions. Where the transfer-pricing order forming the sole basis of the final assessment has been revised pursuant to those directions, an assessment based on the superseded order is unsustainable. The final assessment, consequential demand and penalty-initiation notices were set aside, and the assessment was restored for fresh completion in conformity with the Panel's directions and revised transfer-pricing order.
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