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 ...
Regarding processing of manual refund application, it is held that when genuine issues arise, the Department should adopt a liberal approach, particularly considering that no party would intentionally delay or fail to file refund application in the portal when substantial refund amount is due. The Department should avoid unwarranted litigation on such issues and make the system more assessee-friendly, fostering Revenue's interest in tax collection. In the given case, technicalities should not impede the assessee. The petition is disposed of.
Regarding processing of manual refund application, it is held that when genuine issues arise, the Department should adopt a liberal approach, particularly considering that no party would intentionally delay or fail to file refund application in the portal when substantial refund amount is due. The Department should avoid unwarranted litigation on such issues and make the system more assessee-friendly, fostering Revenue's interest in tax collection. In the given case, technicalities should not impede the assessee. The petition is disposed of.
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