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 ...
Condonation of delay in filing the appeal before the CIT(A) - delay of 636 days - The conduct of the assessee is such that there was clear negligence on its part and there is no equitable ground or substantial cause for condoning the delay of 636 days in filing the appeal before the CIT(A). Therefore, we are of the view that the CIT(A) is correctly dismissed the appeal in limine, without condoning the delay of 636 days in filing the appeal before him. - AT
Condonation of delay in filing the appeal before the CIT(A) - delay of 636 days - The conduct of the assessee is such that there was clear negligence on its part and there is no equitable ground or substantial cause for condoning the delay of 636 days in filing the appeal before the CIT(A). Therefore, we are of the view that the CIT(A) is correctly dismissed the appeal in limine, without condoning the delay of 636 days in filing the appeal before him. - AT
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