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...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Reassessment after four years may proceed where a taxpayer credits a waived retired partner's capital balance but claims its exclusion from taxable income without disclosing supporting facts or the basis of non-taxability. The material states that such omission can amount to failure of full and true disclosure, and recorded reasons need only show a live link to a prima facie belief of escaped income; reassessment was sustained. On taxability, the taxpayer must substantiate the account composition, conversion to unsecured loan, retirement arrangement and waiver, while the assessing authority must identify the charging provision and give reasons. The addition was remanded for de novo, reasoned determination.
Reassessment after four years may proceed where a taxpayer credits a waived retired partner's capital balance but claims its exclusion from taxable income without disclosing supporting facts or the basis of non-taxability. The material states that such omission can amount to failure of full and true disclosure, and recorded reasons need only show a live link to a prima facie belief of escaped income; reassessment was sustained. On taxability, the taxpayer must substantiate the account composition, conversion to unsecured loan, retirement arrangement and waiver, while the assessing authority must identify the charging provision and give reasons. The addition was remanded for de novo, reasoned determination.
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