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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
In closely held companies, share capital credits require proof of identity, creditworthiness and genuineness; mere documentary filing is not enough where enquiries create doubts, and the share capital and premium addition was restored. Alleged commission on accommodation entries could not be sustained on surmise alone, so relief was granted on that item. Sundry creditor transactions required fresh verification because unresolved mismatches and bona fides concerns remained, so the issue was remanded for enquiry. On gross profit, complete deletion was rejected, but the best-judgment estimate was moderated and the rate was directed to be recomputed at 7%.
In closely held companies, share capital credits require proof of identity, creditworthiness and genuineness; mere documentary filing is not enough where enquiries create doubts, and the share capital and premium addition was restored. Alleged commission on accommodation entries could not be sustained on surmise alone, so relief was granted on that item. Sundry creditor transactions required fresh verification because unresolved mismatches and bona fides concerns remained, so the issue was remanded for enquiry. On gross profit, complete deletion was rejected, but the best-judgment estimate was moderated and the rate was directed to be recomputed at 7%.
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