Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Section 50C does not extend to relinquishment of an unregistered contractual right to seek specific performance of an agreement to sell land. Where no sale deed is registered in the transferee's favour and the vendor remains owner, the relinquished right is a capital asset comprising a contractual remedy, not land or building. The deeming fiction is confined to transfers of land or building and cannot be enlarged to cover such rights. A registered leasehold interest was distinguished because it confers possessory and enjoyment rights in rem. The recomputation of long-term capital gain under section 50C and the resulting addition were deleted.
Section 50C does not extend to relinquishment of an unregistered contractual right to seek specific performance of an agreement to sell land. Where no sale deed is registered in the transferee's favour and the vendor remains owner, the relinquished right is a capital asset comprising a contractual remedy, not land or building. The deeming fiction is confined to transfers of land or building and cannot be enlarged to cover such rights. A registered leasehold interest was distinguished because it confers possessory and enjoyment rights in rem. The recomputation of long-term capital gain under section 50C and the resulting addition were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
