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 ...
Disallowance of exemption claimed u/s 54EC - non filling ROI - investment made in REC - assessee has neither filed return of income u/s 139(1) of the Act, nor in response to the notice issued u/s 148 - The tribunal concluded that for claiming exemption under section 54EC of the Income Tax Act, it is not mandatory to file a return of income. - Even at the time of hearing the Ld. DR has not brought our attention to such provision of the Act, suggesting that it is mandatory, for claiming exemption u/s 54EC of the Act, to file the return of income. - AO directed to allow the benefit of exemption.
Disallowance of exemption claimed u/s 54EC - non filling ROI - investment made in REC - assessee has neither filed return of income u/s 139(1) of the Act, nor in response to the notice issued u/s 148 - The tribunal concluded that for claiming exemption under section 54EC of the Income Tax Act, it is not mandatory to file a return of income. - Even at the time of hearing the Ld. DR has not brought our attention to such provision of the Act, suggesting that it is mandatory, for claiming exemption u/s 54EC of the Act, to file the return of income. - AO directed to allow the benefit of exemption.
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