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 ...
Order u/s 201(1)/201(1A) - sufficient opportunity - the date of orders passed by the AO reveal that from the date of issuance of SCN to the date of passing of orders u/s. 201(1) and 201(1A) is less than one month - the information sought by the AO from the assessee is about six years old. It takes time to retrieve the old information - sufficient opportunity was not afforded - matter remanded
Order u/s 201(1)/201(1A) - sufficient opportunity - the date of orders passed by the AO reveal that from the date of issuance of SCN to the date of passing of orders u/s. 201(1) and 201(1A) is less than one month - the information sought by the AO from the assessee is about six years old. It takes time to retrieve the old information - sufficient opportunity was not afforded - matter remanded
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