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 ...
Receipt of advance - Additions u/s 56(2)(vi) - A receipt cannot be taxed merely on conjecture or surmises. - The AO needs to bring on record evidence which proves that the particular receipt is taxable under the provisions of the Act - merely because the person, who paid the amount does not initiate any action for recovery of money should not be not a reason for making addition towards amount received as assessee’s income - AT
Receipt of advance - Additions u/s 56(2)(vi) - A receipt cannot be taxed merely on conjecture or surmises. - The AO needs to bring on record evidence which proves that the particular receipt is taxable under the provisions of the Act - merely because the person, who paid the amount does not initiate any action for recovery of money should not be not a reason for making addition towards amount received as assessee’s income - AT
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