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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Time limitation for passing an order u/s 92CA is a contentious issue. The Tribunal followed the Madras High Court's decision in Pfizer Healthcare, but the Revenue has filed an SLP challenging it before the Supreme Court. Interpretation of Section 92CA's interplay with Section 153 regarding limitation is pending consideration by the Supreme Court. The Bombay High Court's order in PayPal Payments is also challenged before the Supreme Court. To avoid multiplicity of proceedings, the appeals are adjourned sine die, awaiting the Supreme Court's rulings on these issues. Proceeding otherwise would necessitate cross-appeals, adding to the multiplicity.
Time limitation for passing an order u/s 92CA is a contentious issue. The Tribunal followed the Madras High Court's decision in Pfizer Healthcare, but the Revenue has filed an SLP challenging it before the Supreme Court. Interpretation of Section 92CA's interplay with Section 153 regarding limitation is pending consideration by the Supreme Court. The Bombay High Court's order in PayPal Payments is also challenged before the Supreme Court. To avoid multiplicity of proceedings, the appeals are adjourned sine die, awaiting the Supreme Court's rulings on these issues. Proceeding otherwise would necessitate cross-appeals, adding to the multiplicity.
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