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 ...
Section 107(4) gives the Appellate Authority discretion to admit an appeal within the additional one-month condonable period if sufficient cause prevented timely filing. Where an appeal is presented within that period, the authority must examine the explanation for delay on its merits, including uncertainty created by overlapping statutory changes and portal-related constraints. Rejection as time-barred without properly considering that explanation is unsustainable. The appeal was therefore restored for fresh consideration on merits.
Section 107(4) gives the Appellate Authority discretion to admit an appeal within the additional one-month condonable period if sufficient cause prevented timely filing. Where an appeal is presented within that period, the authority must examine the explanation for delay on its merits, including uncertainty created by overlapping statutory changes and portal-related constraints. Rejection as time-barred without properly considering that explanation is unsustainable. The appeal was therefore restored for fresh consideration on merits.
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