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 ...
Undisclosed mutual fund and insurance investments were not treated as wholly unexplained because the assessee had produced balance sheet, capital account, investment statements and supporting land and crop-sale records, although some material remained self-serving and inconsistent. The Tribunal applied the principle that the Act taxes income, not gross receipts, and therefore rejected assessment of the entire investment as deemed income under section 115BBE. It restricted the addition to 5% of the impugned investment figure and directed taxation under the normal provisions instead of deemed-income taxation.
Undisclosed mutual fund and insurance investments were not treated as wholly unexplained because the assessee had produced balance sheet, capital account, investment statements and supporting land and crop-sale records, although some material remained self-serving and inconsistent. The Tribunal applied the principle that the Act taxes income, not gross receipts, and therefore rejected assessment of the entire investment as deemed income under section 115BBE. It restricted the addition to 5% of the impugned investment figure and directed taxation under the normal provisions instead of deemed-income taxation.
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