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 appeal - As the date of dispatch of the order is not available with the department therefore the limitation will start running from the date when the same was received by the Appellant which is 06.03.2020 and after taking into account the Taxation Act, 2020 (supra) read with notification dated 30.09.2020 which extended the time till 31.12.2020 in all the cases due to covid pandemic, the appeal filed on 30.12.2020 was filed well within limitation before the learned Commissioner. - AT
Condonation of delay in filing appeal - As the date of dispatch of the order is not available with the department therefore the limitation will start running from the date when the same was received by the Appellant which is 06.03.2020 and after taking into account the Taxation Act, 2020 (supra) read with notification dated 30.09.2020 which extended the time till 31.12.2020 in all the cases due to covid pandemic, the appeal filed on 30.12.2020 was filed well within limitation before the learned Commissioner. - AT
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