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...
Period of limitation - deeming a person to be an assessee-in-default - Non deduction of TDS - The Tribunal quashed the order dated 31.10.2019 issued u/s201(1) of the Income Tax Act, deeming it to be barred by limitation. The Tribunal followed its earlier decision, which held that amendments made to the statute with effect from 01/10/2014 are prospective, and concluded that the order should have been framed on or before 31.03.2015. As the order was framed on 31.10.2019, it was found to be time-barred. - AT
Period of limitation - deeming a person to be an assessee-in-default - Non deduction of TDS - The Tribunal quashed the order dated 31.10.2019 issued u/s201(1) of the Income Tax Act, deeming it to be barred by limitation. The Tribunal followed its earlier decision, which held that amendments made to the statute with effect from 01/10/2014 are prospective, and concluded that the order should have been framed on or before 31.03.2015. As the order was framed on 31.10.2019, it was found to be time-barred. - AT
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