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 ...
For limitation under section 275(1)(c), the relevant starting point was the date on which the AO recommended initiation of penalty proceedings to the competent authority; the Tribunal treated 11/09/2015 as that date and held that the outer time-limit expired on 31/03/2016. Because the penalty order under section 271C was passed on 19/04/2016, it was time-barred and could not be sustained. The Tribunal therefore quashed the penalty order.
For limitation under section 275(1)(c), the relevant starting point was the date on which the AO recommended initiation of penalty proceedings to the competent authority; the Tribunal treated 11/09/2015 as that date and held that the outer time-limit expired on 31/03/2016. Because the penalty order under section 271C was passed on 19/04/2016, it was time-barred and could not be sustained. The Tribunal therefore quashed the penalty order.
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