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 ...
Surrendered income offered during a survey was accepted as business income at normal rates, and the Tribunal held that the enhanced tax rate under section 115BBE could not be applied for AY 2017-18. Relying on later High Court authority, it treated the higher rate as prospective from 01.04.2017, relevant from AY 2018-19 onwards, and therefore inapplicable to the year in issue. The surrendered sum was directed to be taxed only at normal rates, not at the enhanced rate under section 115BBE.
Surrendered income offered during a survey was accepted as business income at normal rates, and the Tribunal held that the enhanced tax rate under section 115BBE could not be applied for AY 2017-18. Relying on later High Court authority, it treated the higher rate as prospective from 01.04.2017, relevant from AY 2018-19 onwards, and therefore inapplicable to the year in issue. The surrendered sum was directed to be taxed only at normal rates, not at the enhanced rate under section 115BBE.
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