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...
Derivative option losses claimed through a recognised exchange and registered broker require independent proof of genuineness where investigation material indicates manipulated transactions. Contract notes and banking-channel payments alone were insufficient in light of broker admissions, options acquired shortly before expiry and allowed to lapse, and repeated losses; the taxpayer did not rebut this material, so the loss disallowance was sustained. Jurisdictional objections to reassessment, raised specifically before the Tribunal and requiring factual verification, were admitted but remanded to the appellate authority for detailed adjudication. The appeal was partly allowed for statistical purposes.
Derivative option losses claimed through a recognised exchange and registered broker require independent proof of genuineness where investigation material indicates manipulated transactions. Contract notes and banking-channel payments alone were insufficient in light of broker admissions, options acquired shortly before expiry and allowed to lapse, and repeated losses; the taxpayer did not rebut this material, so the loss disallowance was sustained. Jurisdictional objections to reassessment, raised specifically before the Tribunal and requiring factual verification, were admitted but remanded to the appellate authority for detailed adjudication. The appeal was partly allowed for statistical purposes.
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