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 ...
Slump sale u/s 50B or not - Fresh Claim that transaction not liable to capital gain tax - investment in Tax Savings Bonds u/s 54EC - AO, CIT(A) and the Tribunal committed a fundamental error in shutting out the contention raised by the assessee solely on the ground that the assessee approached the Bond Issuing Authorities for availing the benefit u/s 54EC. A careful reading of the submissions made by the assessee before the AO would make things further clear. - There is no estoppel on the part of the assessee to pursue their claim and accordingly, we reject the argument of the Revenue in this regard. - HC
Slump sale u/s 50B or not - Fresh Claim that transaction not liable to capital gain tax - investment in Tax Savings Bonds u/s 54EC - AO, CIT(A) and the Tribunal committed a fundamental error in shutting out the contention raised by the assessee solely on the ground that the assessee approached the Bond Issuing Authorities for availing the benefit u/s 54EC. A careful reading of the submissions made by the assessee before the AO would make things further clear. - There is no estoppel on the part of the assessee to pursue their claim and accordingly, we reject the argument of the Revenue in this regard. - HC
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