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 ...
Condonation of delay in customs appeals requires a bona fide, satisfactory explanation covering the entire period of delay. Although "sufficient cause" receives a liberal, justice-oriented construction, that approach does not excuse gross negligence, lack of diligence or prolonged inaction. Participation through counsel, communication of the adjudication order to counsel, departmental efforts to serve the order, and failure to enquire about the outcome for nearly three years may support refusal of condonation; later receipt of an order copy does not explain earlier inaction. Under the Customs Act, High Court review does not permit reappreciation of such factual findings absent perversity, disregard of material evidence or legal error.
Condonation of delay in customs appeals requires a bona fide, satisfactory explanation covering the entire period of delay. Although "sufficient cause" receives a liberal, justice-oriented construction, that approach does not excuse gross negligence, lack of diligence or prolonged inaction. Participation through counsel, communication of the adjudication order to counsel, departmental efforts to serve the order, and failure to enquire about the outcome for nearly three years may support refusal of condonation; later receipt of an order copy does not explain earlier inaction. Under the Customs Act, High Court review does not permit reappreciation of such factual findings absent perversity, disregard of material evidence or legal error.
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