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 ruled that assessment proceedings were time-barred due to excessive delay in passing remand order by ITAT. The AO failed to issue consequential order within prescribed limitation period. Court directed respondents to grant tax refund for AY 2005-06 with applicable interest under Sections 244A(1) and 244A(1A). The return is deemed accepted, and revenue must process the refund claim expeditiously, preferably within twelve weeks, following precedents in similar cases involving procedural limitations in tax assessment proceedings.
HC ruled that assessment proceedings were time-barred due to excessive delay in passing remand order by ITAT. The AO failed to issue consequential order within prescribed limitation period. Court directed respondents to grant tax refund for AY 2005-06 with applicable interest under Sections 244A(1) and 244A(1A). The return is deemed accepted, and revenue must process the refund claim expeditiously, preferably within twelve weeks, following precedents in similar cases involving procedural limitations in tax assessment proceedings.
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