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 claiming refund based on Tax Deducted at Source [TDS] - As the petitioner is being permitted to file revised returns on condonation of delay, if there is any occasion for the respondents to initiate proceedings u/s 143[2] for framing of assessment u/s 143[3] petitioner must be precluded from raising the defence of limitation. - HC
Condonation of delay in claiming refund based on Tax Deducted at Source [TDS] - As the petitioner is being permitted to file revised returns on condonation of delay, if there is any occasion for the respondents to initiate proceedings u/s 143[2] for framing of assessment u/s 143[3] petitioner must be precluded from raising the defence of limitation. - HC
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