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...
Material evidence on unsecured loans must be considered before sustaining an addition for unexplained cash credits. The High Court noted that the Tribunal did not discuss the assessee's evidence on the lenders' source of funds, made no finding on the explanation of the source of source, and merely repeated the Assessing Officer's conclusions. It also rejected the assessee's cited precedents without examining their factual applicability. The article records that the Tribunal's order on the cash-credit addition was set aside and remanded for fresh consideration after reviewing all material and hearing the parties, with merits left open.
Material evidence on unsecured loans must be considered before sustaining an addition for unexplained cash credits. The High Court noted that the Tribunal did not discuss the assessee's evidence on the lenders' source of funds, made no finding on the explanation of the source of source, and merely repeated the Assessing Officer's conclusions. It also rejected the assessee's cited precedents without examining their factual applicability. The article records that the Tribunal's order on the cash-credit addition was set aside and remanded for fresh consideration after reviewing all material and hearing the parties, with merits left open.
Note: It is a system-generated summary and is for quick reference only.