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 ...
Telescoping of cash recognised in an earlier year as exempt agricultural-land sale proceeds remains available against a later unexplained-money addition unless the Revenue establishes its intervening investment or expenditure. Cash attributed to a non-earning senior citizen mother and minor children may be explained through household savings, pin money, stridhan and customary family gifts; non-filing of returns alone does not discredit such explanations where income does not exceed the non-taxable threshold. The evaluation must account for human probabilities, surrounding circumstances and Indian socio-cultural practices rather than demand commercial records or mathematical precision. The remaining addition for unexplained money was deleted.
Telescoping of cash recognised in an earlier year as exempt agricultural-land sale proceeds remains available against a later unexplained-money addition unless the Revenue establishes its intervening investment or expenditure. Cash attributed to a non-earning senior citizen mother and minor children may be explained through household savings, pin money, stridhan and customary family gifts; non-filing of returns alone does not discredit such explanations where income does not exceed the non-taxable threshold. The evaluation must account for human probabilities, surrounding circumstances and Indian socio-cultural practices rather than demand commercial records or mathematical precision. The remaining addition for unexplained money was deleted.
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