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...
Documentary evidence of a newly inducted partner's capital contribution through banking instruments can discharge the assessee's onus for cash-credit purposes. Where pay-in slips, the partner's capital account and the balance sheet establish that the credit represents partner capital, the absence of a partner confirmation alone does not establish that the explanation is false. Relying on the principle in Pankaj Dyestuff Industries, the High Court treated the unexplained-cash-credit addition as perverse and deleted it, allowing the tax appeal.
Documentary evidence of a newly inducted partner's capital contribution through banking instruments can discharge the assessee's onus for cash-credit purposes. Where pay-in slips, the partner's capital account and the balance sheet establish that the credit represents partner capital, the absence of a partner confirmation alone does not establish that the explanation is false. Relying on the principle in Pankaj Dyestuff Industries, the High Court treated the unexplained-cash-credit addition as perverse and deleted it, allowing the tax appeal.
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