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 ...
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Where Rule 80(3) applies, Form GSTR-9C forms part of the annual return required under Section 44, so filing Form GSTR-9 without the reconciliation statement amounts to failure to furnish the return by the due date. On that basis, late fee under Section 47(2) is attracted for delayed filing of Form GSTR-9C, and the challenge to the levy failed. The HC did not follow Anishia Chandrakanth and upheld the assessment, while leaving the petitioner liberty to pursue an appeal on factual aspects.
Where Rule 80(3) applies, Form GSTR-9C forms part of the annual return required under Section 44, so filing Form GSTR-9 without the reconciliation statement amounts to failure to furnish the return by the due date. On that basis, late fee under Section 47(2) is attracted for delayed filing of Form GSTR-9C, and the challenge to the levy failed. The HC did not follow Anishia Chandrakanth and upheld the assessment, while leaving the petitioner liberty to pursue an appeal on factual aspects.
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