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 ...
The ITAT Ahmedabad, in proceedings u/s 201(1) and 201(1A), found the assessee-in-default for non-deduction of TDS u/s 194IA on property purchases. The assessee failed to provide evidence to support eligibility for proviso to Section 201(1), leading to dismissal of appeal. Interest u/s 201(1A) upheld till payee's return filing. Penalty u/s 271(c) for non-deduction of TDS u/s 194-IA was deemed justified. The appeal was decided against the assessee.
The ITAT Ahmedabad, in proceedings u/s 201(1) and 201(1A), found the assessee-in-default for non-deduction of TDS u/s 194IA on property purchases. The assessee failed to provide evidence to support eligibility for proviso to Section 201(1), leading to dismissal of appeal. Interest u/s 201(1A) upheld till payee's return filing. Penalty u/s 271(c) for non-deduction of TDS u/s 194-IA was deemed justified. The appeal was decided against the assessee.
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