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 High Court held that the appellant is entitled to the benefit of the Amnesty Scheme, 2020 for settlement of tax arrears for the assessment year 2015-16 and for the assessment years 1998-99 to 2004-05. The court emphasized that the appellant should receive the benefit of the method of computation of the Amnesty amount as per the Scheme. The court considered the pendency of a Review Petition and interim orders staying recovery proceedings as relevant factors. The payments made by the appellant during the litigation were deemed provisional and subject to the final outcome. The appeals were disposed of by setting aside previous judgments, quashing orders and demand notices, and declaring the liability of the appellant as settled under the Amnesty Scheme, 2020 through a payment of Rs. 3,19,32,523. The petition was disposed of accordingly.
The High Court held that the appellant is entitled to the benefit of the Amnesty Scheme, 2020 for settlement of tax arrears for the assessment year 2015-16 and for the assessment years 1998-99 to 2004-05. The court emphasized that the appellant should receive the benefit of the method of computation of the Amnesty amount as per the Scheme. The court considered the pendency of a Review Petition and interim orders staying recovery proceedings as relevant factors. The payments made by the appellant during the litigation were deemed provisional and subject to the final outcome. The appeals were disposed of by setting aside previous judgments, quashing orders and demand notices, and declaring the liability of the appellant as settled under the Amnesty Scheme, 2020 through a payment of Rs. 3,19,32,523. The petition was disposed of accordingly.
Note: It is a system-generated summary and is for quick reference only.