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 ...
Extended limitation under Section 74 of the SGST/CGST Act requires a show-cause notice to specifically allege fraud, wilful misstatement, or suppression of material facts with intent to evade tax. A notice issued for the relevant tax period without disclosing these statutory ingredients cannot be sustained. The impugned notice was quashed, while the tax authorities retained liberty to issue a fresh notice in accordance with law.
Extended limitation under Section 74 of the SGST/CGST Act requires a show-cause notice to specifically allege fraud, wilful misstatement, or suppression of material facts with intent to evade tax. A notice issued for the relevant tax period without disclosing these statutory ingredients cannot be sustained. The impugned notice was quashed, while the tax authorities retained liberty to issue a fresh notice in accordance with law.
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