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 ...
Addition u/s 68, u/s 69A and section 69 - In the explanatory memorandum to Notification No. 103/2019, it is certified that no person is being adversely affected by giving retrospective effect to this notification. - In the present case, assessee has duly discharged its tax liability under the IDS, 2016 which is prior to the extended due date as well as before the notification itself and, therefore, there is no occasion to put him in an adverse situation. - AT
Addition u/s 68, u/s 69A and section 69 - In the explanatory memorandum to Notification No. 103/2019, it is certified that no person is being adversely affected by giving retrospective effect to this notification. - In the present case, assessee has duly discharged its tax liability under the IDS, 2016 which is prior to the extended due date as well as before the notification itself and, therefore, there is no occasion to put him in an adverse situation. - AT
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