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 ...
A delayed duplicate TDS re-deposit was treated as a real revenue loss because the second payment, though made under mistake, was beyond time and the payee had already availed credit; the levy of interest was therefore sustained. By contrast, where the assessee had already deposited TDS and filed Form 26QB within time, the later filing was only a mistaken duplication and not an original default in furnishing the statement; late fee under section 234E was therefore deleted. The appeal was partly allowed.
A delayed duplicate TDS re-deposit was treated as a real revenue loss because the second payment, though made under mistake, was beyond time and the payee had already availed credit; the levy of interest was therefore sustained. By contrast, where the assessee had already deposited TDS and filed Form 26QB within time, the later filing was only a mistaken duplication and not an original default in furnishing the statement; late fee under section 234E was therefore deleted. The appeal was partly allowed.
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