Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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A typographical error in the appellate directions led the Assessing Officer to retain part of a section 69 addition for unexplained investment, even though the draft assessment order had made a combined addition for time deposits and reportable transactions. The Tribunal read the reasoning in the directions as showing that both underlying components were meant to be deleted, and treated the differing aggregate figure as a clerical mistake. On that basis, no balance addition could survive in the final assessment order, and the retained amount was deleted.
A typographical error in the appellate directions led the Assessing Officer to retain part of a section 69 addition for unexplained investment, even though the draft assessment order had made a combined addition for time deposits and reportable transactions. The Tribunal read the reasoning in the directions as showing that both underlying components were meant to be deleted, and treated the differing aggregate figure as a clerical mistake. On that basis, no balance addition could survive in the final assessment order, and the retained amount was deleted.
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