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 ...
Interest on non-performing assets of a co-operative bank is not taxable on notional accrual where recovery is uncertain and RBI prudential norms govern recognition, notwithstanding mercantile accounting. Reversal of a provision for bad and doubtful debts on an asset becoming performing is not deemed business income where it is neither recovery of an allowed bad debt nor remission of a loss, expenditure or trading liability. Provisions for standard assets may qualify for deduction as bad-debt provisions, subject to the statutory ceiling; rural advances must be computed using month-end outstanding balances, and fresh provisions cannot be netted against write-backs. Quantification requires fresh verification. Penalty does not arise merely because a disclosed deduction claim fails for lack of a book provision, absent concealment or inaccurate particulars.
Interest on non-performing assets of a co-operative bank is not taxable on notional accrual where recovery is uncertain and RBI prudential norms govern recognition, notwithstanding mercantile accounting. Reversal of a provision for bad and doubtful debts on an asset becoming performing is not deemed business income where it is neither recovery of an allowed bad debt nor remission of a loss, expenditure or trading liability. Provisions for standard assets may qualify for deduction as bad-debt provisions, subject to the statutory ceiling; rural advances must be computed using month-end outstanding balances, and fresh provisions cannot be netted against write-backs. Quantification requires fresh verification. Penalty does not arise merely because a disclosed deduction claim fails for lack of a book provision, absent concealment or inaccurate particulars.
Note: It is a system-generated summary and is for quick reference only.
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