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 ...
Penalty proceedings u/s 271D, 271E and 271AAA - period of limitation - the period of six months from the end of the month in which action for imposition of penalty was initiated ended on 30.06.2011. - Concededly, the penalty order was passed way beyond the later date i.e., 30.06.2011. The record discloses that the penalty order was passed on 30.12.2011. - No penalty - HC
Penalty proceedings u/s 271D, 271E and 271AAA - period of limitation - the period of six months from the end of the month in which action for imposition of penalty was initiated ended on 30.06.2011. - Concededly, the penalty order was passed way beyond the later date i.e., 30.06.2011. The record discloses that the penalty order was passed on 30.12.2011. - No penalty - HC
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