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 u/s. 271(1)(c) for under reporting income - defective notice - The Tribunal agrees with the appellant's argument, emphasizing that the AO did not apply his mind properly while initiating the penalty proceedings - The Tribunal rules in favor of the appellant, stating that the penalty proceedings were not validly initiated due to the lack of clarity in the penalty charge. - As a result, the penalty is deleted for all assessment years under consideration.
Penalty u/s. 271(1)(c) for under reporting income - defective notice - The Tribunal agrees with the appellant's argument, emphasizing that the AO did not apply his mind properly while initiating the penalty proceedings - The Tribunal rules in favor of the appellant, stating that the penalty proceedings were not validly initiated due to the lack of clarity in the penalty charge. - As a result, the penalty is deleted for all assessment years under consideration.
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