Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Interest and other realizations of a co-operative bank under liquidation were held not taxable because section 21(2) of the DICGCI Act required all funds realized to be applied first toward repayment of DICGCI liabilities, leaving the bank with no dominion except for permitted liquidation expenses. The Tribunal applied the doctrine of diversion of income by overriding title and held that the amounts were diverted at source and never accrued as income to the assessee. As income did not accrue, the character of the receipt and the related set-off issue did not survive. The CIT(A)'s deletion of the addition was upheld and the Revenue's appeal failed.
Interest and other realizations of a co-operative bank under liquidation were held not taxable because section 21(2) of the DICGCI Act required all funds realized to be applied first toward repayment of DICGCI liabilities, leaving the bank with no dominion except for permitted liquidation expenses. The Tribunal applied the doctrine of diversion of income by overriding title and held that the amounts were diverted at source and never accrued as income to the assessee. As income did not accrue, the character of the receipt and the related set-off issue did not survive. The CIT(A)'s deletion of the addition was upheld and the Revenue's appeal failed.
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