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 ...
Assessee in Default u/s 201(1) and 201(1A) - period of limitation - non deduction of TDS - the term ‘reasonable period’ in the absence of any statutory limitation cannot be accepted as a straight jacket answer. - Since the CIT(A) and ITAT have accepted the period of limitation to be four (4) years, which in the teeth of the order of the Division Bench in the case of Dr. Reddys Laboratories Limited (supra) cannot be said to be proper, legal or justified. - HC
Assessee in Default u/s 201(1) and 201(1A) - period of limitation - non deduction of TDS - the term ‘reasonable period’ in the absence of any statutory limitation cannot be accepted as a straight jacket answer. - Since the CIT(A) and ITAT have accepted the period of limitation to be four (4) years, which in the teeth of the order of the Division Bench in the case of Dr. Reddys Laboratories Limited (supra) cannot be said to be proper, legal or justified. - HC
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