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 ...
Condonation of delay in filing appeal before Commissioner (Appeals) - time limitation - The appellant received the order on 30.12.2018, making the appeal filed on 22.04.2019 beyond the prescribed period. The contention that the limitation should commence from 22.02.2019, based on subsequent correspondence, was rejected as the order's date remained 14.12.2018, and communication after the order's issuance couldn't alter the appeal timeline. - Consequently, the tribunal dismissed the appeal of the assessee.
Condonation of delay in filing appeal before Commissioner (Appeals) - time limitation - The appellant received the order on 30.12.2018, making the appeal filed on 22.04.2019 beyond the prescribed period. The contention that the limitation should commence from 22.02.2019, based on subsequent correspondence, was rejected as the order's date remained 14.12.2018, and communication after the order's issuance couldn't alter the appeal timeline. - Consequently, the tribunal dismissed the appeal of the assessee.
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