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 - cash expenditure , prior period expenses, provisions for incentive etc. - CIT has not exercised jurisdiction u/s 263 on the ground of ‘no enquiry’ or ‘lack of enquiry’ made by the AO but on conclusions drawn by the AO in allowing expenditure set out in the SCN u/s 263 ought not to have been allowed as deduction - jurisdiction validly invoked
Revision u/s 263 - cash expenditure , prior period expenses, provisions for incentive etc. - CIT has not exercised jurisdiction u/s 263 on the ground of ‘no enquiry’ or ‘lack of enquiry’ made by the AO but on conclusions drawn by the AO in allowing expenditure set out in the SCN u/s 263 ought not to have been allowed as deduction - jurisdiction validly invoked
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