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...
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Foreign life-insurance policy maturity proceeds were not treated as undisclosed foreign income or an undisclosed foreign asset where the investment source was satisfactorily explained. Premiums had been paid from income not chargeable to tax during non-resident status and later from salary already taxed in India; CBDT clarifications on explained foreign assets were stated to apply. The discussion also states that the life-insurance exemption does not confine its benefit to policies issued by Indian insurers. A definition of "insurer" in another provision could not be imported where the exemption provision did not adopt it or distinguish foreign insurers. Accordingly, the maturity proceeds were described as exempt and outside assessment under the Black Money Act.
Foreign life-insurance policy maturity proceeds were not treated as undisclosed foreign income or an undisclosed foreign asset where the investment source was satisfactorily explained. Premiums had been paid from income not chargeable to tax during non-resident status and later from salary already taxed in India; CBDT clarifications on explained foreign assets were stated to apply. The discussion also states that the life-insurance exemption does not confine its benefit to policies issued by Indian insurers. A definition of "insurer" in another provision could not be imported where the exemption provision did not adopt it or distinguish foreign insurers. Accordingly, the maturity proceeds were described as exempt and outside assessment under the Black Money Act.
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