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 levied u/s. 271B - Defective notice - vague and unspecific notice - failure to furnish the audit report u/s 44AB before the due date - Notice proposing penalty should clearly spell out the fault/charge for which the assessee is put on notice, so that he can defend the charge properly. - Further, the explanation given by the assessee cannot be held to be unreasonable. - No penalty since the delay in getting accounts of the earlier year can be reasonable ground as stipulated u/s. 273B
Penalty levied u/s. 271B - Defective notice - vague and unspecific notice - failure to furnish the audit report u/s 44AB before the due date - Notice proposing penalty should clearly spell out the fault/charge for which the assessee is put on notice, so that he can defend the charge properly. - Further, the explanation given by the assessee cannot be held to be unreasonable. - No penalty since the delay in getting accounts of the earlier year can be reasonable ground as stipulated u/s. 273B
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