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 a refund order was unsustainable where it granted refund but did not consider or decide the petitioners' separate claim for accrued interest. The absence of any finding or reason on the interest component showed non-application of mind and failure to pass a reasoned order on an independent claim. The Court did not decide entitlement to interest on merits; it remitted the interest claim for fresh consideration and adjudication in accordance with law, after granting a personal hearing and leaving all contentions open.
HC held that a refund order was unsustainable where it granted refund but did not consider or decide the petitioners' separate claim for accrued interest. The absence of any finding or reason on the interest component showed non-application of mind and failure to pass a reasoned order on an independent claim. The Court did not decide entitlement to interest on merits; it remitted the interest claim for fresh consideration and adjudication in accordance with law, after granting a personal hearing and leaving all contentions open.
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