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...
Bad-debt deduction after 1 April 1989 requires write-off in the accounts and satisfaction of the condition that the debt was considered in computing income; actual irrecoverability need not be established. The notes state that revision under section 263 is impermissible where the assessment record shows that the Assessing Officer examined the claim and supporting evidence. They also explain that reconciled contract receipts cannot be treated as understated merely because bank credits include mobilisation, material or other non-revenue advances. A reasoned assessment order is not required where documentary replies have been examined and accepted.
Bad-debt deduction after 1 April 1989 requires write-off in the accounts and satisfaction of the condition that the debt was considered in computing income; actual irrecoverability need not be established. The notes state that revision under section 263 is impermissible where the assessment record shows that the Assessing Officer examined the claim and supporting evidence. They also explain that reconciled contract receipts cannot be treated as understated merely because bank credits include mobilisation, material or other non-revenue advances. A reasoned assessment order is not required where documentary replies have been examined and accepted.
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