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 ...
Show cause notices must quantify interest liability before demanding it; failure to quantify interest for the specified period in the notice violated the statutory requirement and rendered both the notice and subsequent adjudication order invalid. The court distinguished liability quantified in orders from liability that must be specified in notices, holding that provisions addressing unquantified interest in orders do not cure an unquantified notice. Consequently the impugned notice and demand were quashed, with liberty for tax authorities to issue a fresh, properly quantified show cause notice and proceed in accordance with law.
Show cause notices must quantify interest liability before demanding it; failure to quantify interest for the specified period in the notice violated the statutory requirement and rendered both the notice and subsequent adjudication order invalid. The court distinguished liability quantified in orders from liability that must be specified in notices, holding that provisions addressing unquantified interest in orders do not cure an unquantified notice. Consequently the impugned notice and demand were quashed, with liberty for tax authorities to issue a fresh, properly quantified show cause notice and proceed in accordance with law.
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