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 petitioner contested the levy of interest, claiming tax liability was paid from the credit ledger, precluding interest charges. However, the court observed factual issues requiring detailed scrutiny of records. The petitioner failed to annex the response to the show-cause notice, hindering the court's ability to delve into merits. The statute provides for appellate remedies, with the first appellate authority being functional, albeit the Appellate Tribunal is yet to be constituted. Considering the availability of statutory appellate mechanisms and the need for factual examination, the High Court dismissed the writ petition.
The petitioner contested the levy of interest, claiming tax liability was paid from the credit ledger, precluding interest charges. However, the court observed factual issues requiring detailed scrutiny of records. The petitioner failed to annex the response to the show-cause notice, hindering the court's ability to delve into merits. The statute provides for appellate remedies, with the first appellate authority being functional, albeit the Appellate Tribunal is yet to be constituted. Considering the availability of statutory appellate mechanisms and the need for factual examination, the High Court dismissed the writ petition.
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