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 ...
EPCG Scheme - Failure to fulfill the conditions - export obligation period expired - extension of the period for fulfillment of export obligation - The compelling circumstances beyond their control pointed out by the respondents, have been admitted by the authorities. Therefore, no blame or aspersions can be cast on the respondents that they had malicious intent to defraud the revenue. This argument of the revenue is rejected summarily. - AT
EPCG Scheme - Failure to fulfill the conditions - export obligation period expired - extension of the period for fulfillment of export obligation - The compelling circumstances beyond their control pointed out by the respondents, have been admitted by the authorities. Therefore, no blame or aspersions can be cast on the respondents that they had malicious intent to defraud the revenue. This argument of the revenue is rejected summarily. - AT
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