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...
Penalty u/s 271B - Delay in filing the tax audit report - delay occurred due to the Accountant leaving the job abruptly and it took time for the new Accountant to finalize the accounts - For other years, the assessee was regular in filing the TAR - this is the only year where there is a delay in getting the books of accounts audited u/s 44AB - In the case on hand the tax audit report was filed on 08.03.2018, the return was field on 09.03.2018 and the assessment was completed on 30.12.2019 on which date the tax audit report was very much before the Assessing Officer. Further the assessment was completed accepting the loss returned by the assessee. - No penalty - AT
Penalty u/s 271B - Delay in filing the tax audit report - delay occurred due to the Accountant leaving the job abruptly and it took time for the new Accountant to finalize the accounts - For other years, the assessee was regular in filing the TAR - this is the only year where there is a delay in getting the books of accounts audited u/s 44AB - In the case on hand the tax audit report was filed on 08.03.2018, the return was field on 09.03.2018 and the assessment was completed on 30.12.2019 on which date the tax audit report was very much before the Assessing Officer. Further the assessment was completed accepting the loss returned by the assessee. - No penalty - AT
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