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...
Exemption u/s 11 - deemed grant of registration - The period of six months referred in Section 12AA(2) has to be calculated from the end of the months in which the application u/s 12A was received and not from any other date. - Tribunal was not justified in applying Section 12AA(2) of the Act, 1961 in the facts of the present case and the order of CIT could not have been set aside on this ground. The decision of the Tribunal is based on a misreading and misunderstanding of Section 12AA(2) of the Act, 1961, its purport and scope. - HC
Exemption u/s 11 - deemed grant of registration - The period of six months referred in Section 12AA(2) has to be calculated from the end of the months in which the application u/s 12A was received and not from any other date. - Tribunal was not justified in applying Section 12AA(2) of the Act, 1961 in the facts of the present case and the order of CIT could not have been set aside on this ground. The decision of the Tribunal is based on a misreading and misunderstanding of Section 12AA(2) of the Act, 1961, its purport and scope. - HC
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