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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
The High Court held that once an appeal by the Revenue is included in the application for settlement under the Direct Tax Vivad Se Vishwas Act, 2020 (VSV Act), all disputes forming the subject matter of that appeal and the potential outcome become subject to closure and discontinuance. The tax liability arising from such appeal sets is governed exclusively by the VSV Act. The issuance of the certificate u/s 5 of the VSV Act renders both appeals closed and all aspects of disputation rendered quietus. The Court rejected the claim for statutory interest u/s 244A of the Income Tax Act. However, it directed the respondents to pay interest at 5% per annum on account of the delay in releasing the amount determined under the VSV Act, for the period between February/November 2021 to February 2023.
The High Court held that once an appeal by the Revenue is included in the application for settlement under the Direct Tax Vivad Se Vishwas Act, 2020 (VSV Act), all disputes forming the subject matter of that appeal and the potential outcome become subject to closure and discontinuance. The tax liability arising from such appeal sets is governed exclusively by the VSV Act. The issuance of the certificate u/s 5 of the VSV Act renders both appeals closed and all aspects of disputation rendered quietus. The Court rejected the claim for statutory interest u/s 244A of the Income Tax Act. However, it directed the respondents to pay interest at 5% per annum on account of the delay in releasing the amount determined under the VSV Act, for the period between February/November 2021 to February 2023.
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