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 ...
Revision u/s 263 - Gain on cancellation of forwarding contract - characterization of income - Revenue may be correct in contending that, the Assessing Officer had not carried out detailed enquiries that by itself would not be sufficient to enable the Commissioner to exercise revisional power if based on materials already on record come to the same conclusion that amount is capital nature and not taxable.
Revision u/s 263 - Gain on cancellation of forwarding contract - characterization of income - Revenue may be correct in contending that, the Assessing Officer had not carried out detailed enquiries that by itself would not be sufficient to enable the Commissioner to exercise revisional power if based on materials already on record come to the same conclusion that amount is capital nature and not taxable.
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