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 for passing adjudication order - when there is a clear observation of the hon’ble High Court in the present case itself that will prevail over the board circular which was relied upon by the learned Commissioner (Appeals) - the observation of hon’ble High Court will prevail over the board circular and according to which the Joint Commissioner has jurisdiction not only to issue the Show Cause Notice but also to adjudicate the same. - AT
Jurisdiction for passing adjudication order - when there is a clear observation of the hon’ble High Court in the present case itself that will prevail over the board circular which was relied upon by the learned Commissioner (Appeals) - the observation of hon’ble High Court will prevail over the board circular and according to which the Joint Commissioner has jurisdiction not only to issue the Show Cause Notice but also to adjudicate the same. - AT
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