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 ...
Advance Ruling application on maintainability - Reversal of input tax credit to extent of tax element in credit note - no agreement between parties on credit notes not treated as financial/commercial credit notes - no agreement to reduce ITC claim - mismatch of ITC claim figures between GSTR-3B and GSTR-2A - impact of incorrect output tax liability reduction based on credit note issued. Questions on ITC reversal based on credit notes and eligibility to claim ITC based on original invoices admissible u/s 97(2)(d) of CGST Act. Questions on ITC rejection due to GSTR-3B and GSTR-2A mismatch and impact of supplier's incorrect output tax liability reduction on applicant's ITC not covered u/s 97(2). Applicant issued notice u/s 61 for discrepancies, advance ruling filed later. Proceedings pending against applicant, application liable to be rejected u/s 98(2) first proviso.
Advance Ruling application on maintainability - Reversal of input tax credit to extent of tax element in credit note - no agreement between parties on credit notes not treated as financial/commercial credit notes - no agreement to reduce ITC claim - mismatch of ITC claim figures between GSTR-3B and GSTR-2A - impact of incorrect output tax liability reduction based on credit note issued. Questions on ITC reversal based on credit notes and eligibility to claim ITC based on original invoices admissible u/s 97(2)(d) of CGST Act. Questions on ITC rejection due to GSTR-3B and GSTR-2A mismatch and impact of supplier's incorrect output tax liability reduction on applicant's ITC not covered u/s 97(2). Applicant issued notice u/s 61 for discrepancies, advance ruling filed later. Proceedings pending against applicant, application liable to be rejected u/s 98(2) first proviso.
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