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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 AT allowed the appeal, holding the impugned attachment and freeze unlawful for breach of natural justice due to non-supply of relied-upon documents (RUDs) with the show-cause notice; several RUDs, including investigative reports and FIRs, were integral to the reasons to believe and were not furnished. The Tribunal found that peripheral factual disputes (shareholding quantum, timing/repayment of loans, proprietary rights, and proportionality of seizure) became moot once procedural illegality was established. The respondents are directed to return seized movable assets, digital devices and records and to de-freeze the appellant's bank accounts within six weeks of receipt of a certified copy of this order. Appeal allowed.
The AT allowed the appeal, holding the impugned attachment and freeze unlawful for breach of natural justice due to non-supply of relied-upon documents (RUDs) with the show-cause notice; several RUDs, including investigative reports and FIRs, were integral to the reasons to believe and were not furnished. The Tribunal found that peripheral factual disputes (shareholding quantum, timing/repayment of loans, proprietary rights, and proportionality of seizure) became moot once procedural illegality was established. The respondents are directed to return seized movable assets, digital devices and records and to de-freeze the appellant's bank accounts within six weeks of receipt of a certified copy of this order. Appeal allowed.
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