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 of 1085 days in filing the appeal u/s 260-A - Revenue's appeal - The court found that the appellant failed to provide a valid explanation for the delay of 1085 days in filing the appeal. Despite the previous appeal being declared infructuous, the court held that it had no relevance to the current appeal, as they pertained to different orders. The court cited a precedent to emphasize that negligence in prosecuting the matter cannot be condoned merely because the government is a party. It highlighted the need for plausible and acceptable explanations for delays.
Condonation of delay of 1085 days in filing the appeal u/s 260-A - Revenue's appeal - The court found that the appellant failed to provide a valid explanation for the delay of 1085 days in filing the appeal. Despite the previous appeal being declared infructuous, the court held that it had no relevance to the current appeal, as they pertained to different orders. The court cited a precedent to emphasize that negligence in prosecuting the matter cannot be condoned merely because the government is a party. It highlighted the need for plausible and acceptable explanations for delays.
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