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 ...
Validity of show cause notice (SCN) - Supply of Relied Upon Documents (RUD) - Supply of inter-departmental communications or records/file notings or data/information - The High court found a prima facie case for the petitioners to be provided with the investigation report, acknowledging that such disclosure must balance the need for transparency and the protection of sensitive information. The court directed the respondents to furnish the investigation report to the petitioners, with the possibility of redacting sensitive information. - The court dismissed the demands for additional documents as unfounded and a means to delay the proceedings. It affirmed the need for transparency and the right to a fair defense, within the bounds of reasonable requests and the avoidance of fishing expeditions.
Validity of show cause notice (SCN) - Supply of Relied Upon Documents (RUD) - Supply of inter-departmental communications or records/file notings or data/information - The High court found a prima facie case for the petitioners to be provided with the investigation report, acknowledging that such disclosure must balance the need for transparency and the protection of sensitive information. The court directed the respondents to furnish the investigation report to the petitioners, with the possibility of redacting sensitive information. - The court dismissed the demands for additional documents as unfounded and a means to delay the proceedings. It affirmed the need for transparency and the right to a fair defense, within the bounds of reasonable requests and the avoidance of fishing expeditions.
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