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...
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Rectification application - Validity of Garnishee Notices for recovery of tax - contention of the writ petitioners that the Garnishee Notices had come to be issued even though various applications for rectification were pending and the respondents having adopted coercive measures without disposing of those applications - The High Court observed that, since Garnishee Notices already operate, we take note of the additional prayer made by the writ petitioner of it being permitted to securitize 20% of the outstanding tax demand by submitting an undertaking that it would maintain a credit balance in the aforenoted accounts to the extent of INR 3,43,37,076/- being 20% of the total outstanding demand till such time as the rectification applications are disposed of.
Rectification application - Validity of Garnishee Notices for recovery of tax - contention of the writ petitioners that the Garnishee Notices had come to be issued even though various applications for rectification were pending and the respondents having adopted coercive measures without disposing of those applications - The High Court observed that, since Garnishee Notices already operate, we take note of the additional prayer made by the writ petitioner of it being permitted to securitize 20% of the outstanding tax demand by submitting an undertaking that it would maintain a credit balance in the aforenoted accounts to the extent of INR 3,43,37,076/- being 20% of the total outstanding demand till such time as the rectification applications are disposed of.
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