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 ...
Interest u/s. 244A - interest on unpaid interest - refund awarded in the rectification order u/s. 154 - The appellant contested the decision of the Commissioner of Income Tax (Appeals), emphasizing their entitlement to interest from April 1, 2017, onwards. Despite initial denial by the Assessing Officer, the Tribunal ruled in favor of the appellant, considering the rectification order and the acceptance of Minimum Alternate Tax (MAT) credit. The Tribunal's decision aligned with the appellant's interpretation of section 244A, leading to the allowance of interest from the start of the assessment year to the date of refund.
Interest u/s. 244A - interest on unpaid interest - refund awarded in the rectification order u/s. 154 - The appellant contested the decision of the Commissioner of Income Tax (Appeals), emphasizing their entitlement to interest from April 1, 2017, onwards. Despite initial denial by the Assessing Officer, the Tribunal ruled in favor of the appellant, considering the rectification order and the acceptance of Minimum Alternate Tax (MAT) credit. The Tribunal's decision aligned with the appellant's interpretation of section 244A, leading to the allowance of interest from the start of the assessment year to the date of refund.
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