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 u/s 272A(2)(k) - assessee did not file its quarterly TDS returns within the prescribed time limit and there was a delay - In the given case, the assessee did not assess the liability under TDS provisions and subsequent to the survey, he blindly followed the instructions of the officers and remitted the liability in cash through SBI without taking any details of determination of liability. - Subsequently, the assessee could not comply with the filing of quarterly returns and made to pay the same amount again. The above situation clearly proves the reasonable cause. - AT
Penalty u/s 272A(2)(k) - assessee did not file its quarterly TDS returns within the prescribed time limit and there was a delay - In the given case, the assessee did not assess the liability under TDS provisions and subsequent to the survey, he blindly followed the instructions of the officers and remitted the liability in cash through SBI without taking any details of determination of liability. - Subsequently, the assessee could not comply with the filing of quarterly returns and made to pay the same amount again. The above situation clearly proves the reasonable cause. - AT
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