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 ...
Non-filing of returns by some suppliers, without further enquiry or contrary material, was held insufficient to reject recorded purchases where payments were through banking channels and sales were accepted; the ad hoc gross profit addition on disputed purchases was deleted. For unaccounted sales, only the profit element was treated as taxable, and the income was estimated on a net profit basis at 2% rather than by taxing the entire sales. Alleged entry-fee receipts based on extrapolation from a limited period were curtailed, with only 25% of the estimated addition sustained. Separate addition for unexplained expenditure was deleted on telescoping, as the sustained undisclosed income was treated as available to meet that expenditure.
Non-filing of returns by some suppliers, without further enquiry or contrary material, was held insufficient to reject recorded purchases where payments were through banking channels and sales were accepted; the ad hoc gross profit addition on disputed purchases was deleted. For unaccounted sales, only the profit element was treated as taxable, and the income was estimated on a net profit basis at 2% rather than by taxing the entire sales. Alleged entry-fee receipts based on extrapolation from a limited period were curtailed, with only 25% of the estimated addition sustained. Separate addition for unexplained expenditure was deleted on telescoping, as the sustained undisclosed income was treated as available to meet that expenditure.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
