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 ...
Penalty imposed u/s 271(1)(c) - satisfaction relates to Section 271AAA - satisfaction of the AO qua a wrong section for the purposes of penalty of strict nature is clearly no satisfaction in the eyes of law. The whole action of the AO carried under s. 271(1)(c) is thus vitiated and a nullity in law.
Penalty imposed u/s 271(1)(c) - satisfaction relates to Section 271AAA - satisfaction of the AO qua a wrong section for the purposes of penalty of strict nature is clearly no satisfaction in the eyes of law. The whole action of the AO carried under s. 271(1)(c) is thus vitiated and a nullity in law.
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