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 the Revenue's income-tax appeal depends on whether sufficient cause is shown through a bona fide and adequately explained process, rather than on the length of delay alone. Departmental scrutiny, approvals, record collection and preparation of the appeal memorandum may constitute sufficient cause where the explanation is not specifically denied or shown to be non-existent. Handwritten dates in an otherwise standard-form delay application do not by themselves establish that the explanation is stereotyped or unreliable when the application materially accounts for the delay. On these facts, the departmental procedural delay was treated as bona fide, the delay was condoned, and the appeal was directed for admission processing.
Condonation of delay in the Revenue's income-tax appeal depends on whether sufficient cause is shown through a bona fide and adequately explained process, rather than on the length of delay alone. Departmental scrutiny, approvals, record collection and preparation of the appeal memorandum may constitute sufficient cause where the explanation is not specifically denied or shown to be non-existent. Handwritten dates in an otherwise standard-form delay application do not by themselves establish that the explanation is stereotyped or unreliable when the application materially accounts for the delay. On these facts, the departmental procedural delay was treated as bona fide, the delay was condoned, and the appeal was directed for admission processing.
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