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...
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Section 115BBE applies only to income properly brought within the deeming provisions in sections 68 to 69D; it does not independently tax income merely because it was surrendered or undisclosed during a survey. Each deeming provision has distinct foundational conditions that must be identified and satisfied. Where the assessment neither invoked a relevant deeming provision nor established that the surrendered income fell within sections 68 to 69D, the special rate cannot apply. The surrendered income was therefore taxable at the assessee's normal applicable rate.
Section 115BBE applies only to income properly brought within the deeming provisions in sections 68 to 69D; it does not independently tax income merely because it was surrendered or undisclosed during a survey. Each deeming provision has distinct foundational conditions that must be identified and satisfied. Where the assessment neither invoked a relevant deeming provision nor established that the surrendered income fell within sections 68 to 69D, the special rate cannot apply. The surrendered income was therefore taxable at the assessee's normal applicable rate.
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