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 ...
HC held that Section 50C's applicability extends beyond traditional ownership, encompassing various modes of property holding including leasehold rights. The term "held by an assessee" is interpreted broadly to include multiple legal arrangements such as leasehold, sub-leasehold, tenancy, and licensee interests. The court emphasized that the method of holding land does not create exceptions to tax provisions. The word 'transfer' under Section 50C must be construed with wide amplitude, covering all legally permissible transfer methods. Consequently, the court dismissed the appeal, affirming a comprehensive interpretation of property transfer and taxation principles.
HC held that Section 50C's applicability extends beyond traditional ownership, encompassing various modes of property holding including leasehold rights. The term "held by an assessee" is interpreted broadly to include multiple legal arrangements such as leasehold, sub-leasehold, tenancy, and licensee interests. The court emphasized that the method of holding land does not create exceptions to tax provisions. The word 'transfer' under Section 50C must be construed with wide amplitude, covering all legally permissible transfer methods. Consequently, the court dismissed the appeal, affirming a comprehensive interpretation of property transfer and taxation principles.
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