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 ...
Eligibility for settlement under DTVSV Act - Delay in filing appeal - Pending appeal before ITAT - Specified date under DTVSV Act - The High Court observed that Section 2 (1) (a) (ii) of the DTVSV Act includes cases where the time limit for filing an appeal had not expired on the specified date, making the assessee eligible for settlement benefits. - The DTVSV Act is aimed at resolving tax disputes and ensuring timely revenue collection. The specified date is 31.01.2020. The legislative intent, as evident from the Finance Minister’s speech and the Statement of Objects and Reasons, was to bring finality to tax disputes and reduce litigation. Thus, the interpretation of the DTVSV Act should be liberal and purposive, extending its benefits to eligible taxpayers. - The Delhi High Court ruled in favor of the assessee, allowing the application under the DTVSV Act.
Eligibility for settlement under DTVSV Act - Delay in filing appeal - Pending appeal before ITAT - Specified date under DTVSV Act - The High Court observed that Section 2 (1) (a) (ii) of the DTVSV Act includes cases where the time limit for filing an appeal had not expired on the specified date, making the assessee eligible for settlement benefits. - The DTVSV Act is aimed at resolving tax disputes and ensuring timely revenue collection. The specified date is 31.01.2020. The legislative intent, as evident from the Finance Minister’s speech and the Statement of Objects and Reasons, was to bring finality to tax disputes and reduce litigation. Thus, the interpretation of the DTVSV Act should be liberal and purposive, extending its benefits to eligible taxpayers. - The Delhi High Court ruled in favor of the assessee, allowing the application under the DTVSV Act.
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