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...
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The ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
The ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
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