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 ...
Levy of penalty u/s 271C - Whether appellant is entitled to immunity from penalty as the appellant has opted for VSVS in respect of order u/s 201(1)? - Since the dispute is related to the quantum of 201(1) proceedings the same is already settled and therefore, penalty cannot be imposed subsequently under Section 271C of the Act. - AT
Levy of penalty u/s 271C - Whether appellant is entitled to immunity from penalty as the appellant has opted for VSVS in respect of order u/s 201(1)? - Since the dispute is related to the quantum of 201(1) proceedings the same is already settled and therefore, penalty cannot be imposed subsequently under Section 271C of the Act. - AT
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