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 ...
Jurisdiction - proper officer for issuance of SCN - DRI is proper officer or not - the show cause notice was issued by the Additional Director General, DRI under Section 28 ibid, which as per the aforesaid decision of the Hon’ble Supreme Court is without any authority of law and therefore the Appeals also deserve to be allowed on this ground itself. - AT
Jurisdiction - proper officer for issuance of SCN - DRI is proper officer or not - the show cause notice was issued by the Additional Director General, DRI under Section 28 ibid, which as per the aforesaid decision of the Hon’ble Supreme Court is without any authority of law and therefore the Appeals also deserve to be allowed on this ground itself. - AT
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