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 ...
Validity of SCN - Admittedly, no such SCN is found in the file. Once, there is no such SCN found in the file, then, there was no sanction in law to make an Order-in-Original, particularly, after the period of nearly 18 years from the date of filing of the Bill of Entry and 12 ½ years from the date of the assessment, as contemplated by Sub-sections (1) and (2) of Section 18. - HC
Validity of SCN - Admittedly, no such SCN is found in the file. Once, there is no such SCN found in the file, then, there was no sanction in law to make an Order-in-Original, particularly, after the period of nearly 18 years from the date of filing of the Bill of Entry and 12 ½ years from the date of the assessment, as contemplated by Sub-sections (1) and (2) of Section 18. - HC
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