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 for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
Reassessment for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
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