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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Condonation of delay - sufficient cause - Request for Reopening of assessment order for accepting declarations in Form ‘C’ - power of authorities to reopen the proceedings after lapse of four years - no material particulars are placed on record with regard to the date of such closure - as no ‘sufficient cause’ has been made out by the petitioner to explain the delay in filing declarations in Form ‘C’, we are of the opinion no case for directing to reopen the assessment is made out. - HC
Condonation of delay - sufficient cause - Request for Reopening of assessment order for accepting declarations in Form ‘C’ - power of authorities to reopen the proceedings after lapse of four years - no material particulars are placed on record with regard to the date of such closure - as no ‘sufficient cause’ has been made out by the petitioner to explain the delay in filing declarations in Form ‘C’, we are of the opinion no case for directing to reopen the assessment is made out. - HC
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