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 Tribunal held that late filing fee u/s 234E was not leviable on the assessee. The assessee had filed the relevant return within the due date on 22.10.2021, which was acknowledged by the Central Processing Centre. The subsequent filing on 26.07.2022 was due to a technical glitch on the department's portal to facilitate issuance of TDS certificates for clients. The Tribunal ruled that the return filed on 22.10.2021 cannot be ignored, and late filing fee cannot be levied on the return filed on 26.07.2022. Consequently, the late filing fee imposed was deleted, and the assessee's appeal was allowed.
The Tribunal held that late filing fee u/s 234E was not leviable on the assessee. The assessee had filed the relevant return within the due date on 22.10.2021, which was acknowledged by the Central Processing Centre. The subsequent filing on 26.07.2022 was due to a technical glitch on the department's portal to facilitate issuance of TDS certificates for clients. The Tribunal ruled that the return filed on 22.10.2021 cannot be ignored, and late filing fee cannot be levied on the return filed on 26.07.2022. Consequently, the late filing fee imposed was deleted, and the assessee's appeal was allowed.
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