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 ...
Scope of SCN - lack of jurisdiction - it is submitted that, passing orders, disposing of the SCNs in a hurry only to pre-empt today's hearing and to present the Court with a fait accompli - The Court finds this is to be extraordinary. It unmistakably reflects the anxiety of the Officer in question who has issued the SCNs to proceed to dispose them of hurriedly and thus preempt the hearing before this Court - This Court would not like to presume that statutory authorities would be unmindful of their statutory responsibilities of determining every SCN in an objective and impartial manner on the basis of the facts presented before them, addressing all the legal submissions made in response to the SCN. - HC
Scope of SCN - lack of jurisdiction - it is submitted that, passing orders, disposing of the SCNs in a hurry only to pre-empt today's hearing and to present the Court with a fait accompli - The Court finds this is to be extraordinary. It unmistakably reflects the anxiety of the Officer in question who has issued the SCNs to proceed to dispose them of hurriedly and thus preempt the hearing before this Court - This Court would not like to presume that statutory authorities would be unmindful of their statutory responsibilities of determining every SCN in an objective and impartial manner on the basis of the facts presented before them, addressing all the legal submissions made in response to the SCN. - HC
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