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 ...
SVLDRS - Recovery of arrears of tax in terms of Section 124(1)(c) of the Sabka Vishwas (Legacy Dispute Resolution Scheme Rules, 2019 in the Finance Act, 2019 - jurisdiction under Section 74 of the Finance Act, 1994 was invoked to rectify the mistake - The High court found that initiating a rectification proceeding under Section 74 cannot be equated with filing an appeal under Section 86 of the Finance Act, 1994. Therefore, the petitioner’s case could not be considered under the appeal category for SVLDRS relief, which necessitates a different calculation of the dues. - The court allowed the settlement under SVLDRS upon payment of the due amount and interest.
SVLDRS - Recovery of arrears of tax in terms of Section 124(1)(c) of the Sabka Vishwas (Legacy Dispute Resolution Scheme Rules, 2019 in the Finance Act, 2019 - jurisdiction under Section 74 of the Finance Act, 1994 was invoked to rectify the mistake - The High court found that initiating a rectification proceeding under Section 74 cannot be equated with filing an appeal under Section 86 of the Finance Act, 1994. Therefore, the petitioner’s case could not be considered under the appeal category for SVLDRS relief, which necessitates a different calculation of the dues. - The court allowed the settlement under SVLDRS upon payment of the due amount and interest.
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