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...
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Where a show cause notice under Section 74(1) is founded on documents from an earlier search and seizure, the noticee must be given effective access to the relied upon material to answer it. The Court held that the petitioners were entitled to inspection and/or extracts of all relied upon records, and that specific accounting data such as excel or tally files had to be supplied where relied upon and specifically requested. It limited the ruling to this procedural access issue, directed disclosure within the time fixed, allowed time to reply and a personal hearing, extended the adjudication period, and left all other challenges open.
Where a show cause notice under Section 74(1) is founded on documents from an earlier search and seizure, the noticee must be given effective access to the relied upon material to answer it. The Court held that the petitioners were entitled to inspection and/or extracts of all relied upon records, and that specific accounting data such as excel or tally files had to be supplied where relied upon and specifically requested. It limited the ruling to this procedural access issue, directed disclosure within the time fixed, allowed time to reply and a personal hearing, extended the adjudication period, and left all other challenges open.
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