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 ...
Deduction u/s. 80IB(10) - non filling of return on time - the ITAT held that the return filed beyond the due date cannot claim deduction under section 80IB(10) as per the Supreme Court's decision in Wipro Ltd. vs. Pr. CIT. - The ITAT further observed that, the reasoning given by the assessee that within a period of six months from the date of filing of return of income for assessment year 2006- 07, the assessee have filed return of income for assessment year 2007-08 will not help the assessee as the assessee was very well aware of mandatory date of filing the original return of income.
Deduction u/s. 80IB(10) - non filling of return on time - the ITAT held that the return filed beyond the due date cannot claim deduction under section 80IB(10) as per the Supreme Court's decision in Wipro Ltd. vs. Pr. CIT. - The ITAT further observed that, the reasoning given by the assessee that within a period of six months from the date of filing of return of income for assessment year 2006- 07, the assessee have filed return of income for assessment year 2007-08 will not help the assessee as the assessee was very well aware of mandatory date of filing the original return of income.
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