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...
Dealing-error losses incurred by a share broker in client transactions are described as allowable where reassessment proceedings examined and accepted their genuineness, with no factual or legal defect identified in the appellate findings. The text also treats losses on proprietary derivative transactions as realised business losses where contract notes, transaction-wise details and contemporaneous records establish that positions were squared off during the relevant year. A corrected factual explanation, supported by evidence, prevails over an initial statement that the loss arose from an open position; compulsory cash settlement supports treatment as realised rather than notional loss.
Dealing-error losses incurred by a share broker in client transactions are described as allowable where reassessment proceedings examined and accepted their genuineness, with no factual or legal defect identified in the appellate findings. The text also treats losses on proprietary derivative transactions as realised business losses where contract notes, transaction-wise details and contemporaneous records establish that positions were squared off during the relevant year. A corrected factual explanation, supported by evidence, prevails over an initial statement that the loss arose from an open position; compulsory cash settlement supports treatment as realised rather than notional loss.
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