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 u/s 271(1)(c) - while declining deduction u/s 80IA no defect was pointed out by the A.O. with regard to assessee’s eligibility save and except there was delay in filing return of income - raising a bona fide legal claim, even if it is ultimately found to be legally not acceptable, could not amount to concealing particulars of income or furnishing of inaccurate particulars of income - no penalty
Penalty u/s 271(1)(c) - while declining deduction u/s 80IA no defect was pointed out by the A.O. with regard to assessee’s eligibility save and except there was delay in filing return of income - raising a bona fide legal claim, even if it is ultimately found to be legally not acceptable, could not amount to concealing particulars of income or furnishing of inaccurate particulars of income - no penalty
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