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 ...
Inordinate delay in adjudication of show cause notice by revenue authorities constitutes breach of fair procedure and violates principles of natural justice, causing prejudice to petitioners. Adjudicating authorities are obligated to adjudicate within reasonable time, failure of which warrants quashing of delayed adjudications lacking compelling justification. Unreasonable delay renders it impossible for petitioners to plan business or account for contingent liabilities, thereby breaching procedural fairness mandated in fiscal matters. Precedents establish that such egregious delays without cogent explanations necessitate quashing of impugned adjudications by High Court to uphold principles of natural justice.
Inordinate delay in adjudication of show cause notice by revenue authorities constitutes breach of fair procedure and violates principles of natural justice, causing prejudice to petitioners. Adjudicating authorities are obligated to adjudicate within reasonable time, failure of which warrants quashing of delayed adjudications lacking compelling justification. Unreasonable delay renders it impossible for petitioners to plan business or account for contingent liabilities, thereby breaching procedural fairness mandated in fiscal matters. Precedents establish that such egregious delays without cogent explanations necessitate quashing of impugned adjudications by High Court to uphold principles of natural justice.
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