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...
Unsupported claims for expenditure against commission income cannot be accepted solely on the taxpayer's assertions. The text explains that, despite the absence of documentary evidence, the nature of commission activities, the taxpayer's age, cash withdrawals and the scale of commission receipts indicated that substantial expenditure on assistance, administrative needs and incidental items was inevitable. It considers an estimate of 10 per cent of gross commission receipts inadequate and prescribes allowance of expenditure at 20 per cent, requiring consequential recomputation of income.
Unsupported claims for expenditure against commission income cannot be accepted solely on the taxpayer's assertions. The text explains that, despite the absence of documentary evidence, the nature of commission activities, the taxpayer's age, cash withdrawals and the scale of commission receipts indicated that substantial expenditure on assistance, administrative needs and incidental items was inevitable. It considers an estimate of 10 per cent of gross commission receipts inadequate and prescribes allowance of expenditure at 20 per cent, requiring consequential recomputation of income.
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