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 ...
Reassessment based on search-related information may be initiated under reassessment provisions where the Assessing Officer also relies on independent enquiries into transactions with an alleged entry provider, rather than on search material alone. Approval for the reassessment notice was treated as procedurally valid and non-mechanical, and the challenge to reassessment failed. Where sales are accepted but purchases from an alleged accommodation-entry provider remain unverifiable, the entire purchase amount need not be disallowed, particularly where the relied-on statement was retracted. The addition was confined to the profit element reflected in the taxpayer's gross-profit position, fixed at 6% of the disputed purchases. The appeal was partly allowed on the quantum of addition.
Reassessment based on search-related information may be initiated under reassessment provisions where the Assessing Officer also relies on independent enquiries into transactions with an alleged entry provider, rather than on search material alone. Approval for the reassessment notice was treated as procedurally valid and non-mechanical, and the challenge to reassessment failed. Where sales are accepted but purchases from an alleged accommodation-entry provider remain unverifiable, the entire purchase amount need not be disallowed, particularly where the relied-on statement was retracted. The addition was confined to the profit element reflected in the taxpayer's gross-profit position, fixed at 6% of the disputed purchases. The appeal was partly allowed on the quantum of addition.
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