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 ...
Territorial Jurisdiction - seeking transfer of place of investigation - The petitioner cited inconvenience due to the distance between their headquarters in Thiruvananthapuram and the location of the investigation in Kasaragod. However, the court found no compelling reason to grant the transfer, noting that Kasaragod is within the boundaries of Kerala. Consequently, the court dismissed this plea. - On the matter of expediting the advance ruling application, the court noted that the application was relatively recent, filed in January 2024. Therefore, the court declined to intervene and compel the advance ruling authority to expedite the decision.
Territorial Jurisdiction - seeking transfer of place of investigation - The petitioner cited inconvenience due to the distance between their headquarters in Thiruvananthapuram and the location of the investigation in Kasaragod. However, the court found no compelling reason to grant the transfer, noting that Kasaragod is within the boundaries of Kerala. Consequently, the court dismissed this plea. - On the matter of expediting the advance ruling application, the court noted that the application was relatively recent, filed in January 2024. Therefore, the court declined to intervene and compel the advance ruling authority to expedite the decision.
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