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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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Consequential assessment orders allowing verified purchase expenditure in full bind the Department, leaving it without an aggrieved claim against the allowance. Where an earlier remand required fresh inquiry into allegedly unsubstantiated or inflated purchases, the Assessing Officer's subsequent verification and full acceptance of the claims rendered the surviving purchase-disallowance controversy infructuous. A favourable remand report, and more strongly a consequential assessment order, prevents the Department from contesting the allowance. The purchase disallowances partly sustained at first appeal were therefore deleted fully, the assessee's appeals succeeded on this issue, and the corresponding Revenue grounds failed.
Consequential assessment orders allowing verified purchase expenditure in full bind the Department, leaving it without an aggrieved claim against the allowance. Where an earlier remand required fresh inquiry into allegedly unsubstantiated or inflated purchases, the Assessing Officer's subsequent verification and full acceptance of the claims rendered the surviving purchase-disallowance controversy infructuous. A favourable remand report, and more strongly a consequential assessment order, prevents the Department from contesting the allowance. The purchase disallowances partly sustained at first appeal were therefore deleted fully, the assessee's appeals succeeded on this issue, and the corresponding Revenue grounds failed.
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