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...
Revision u/s 263 - lack of enquiry - Deemed dividend u/s 2(22)(e) - AO had not only made the enquiry or verification to ascertain the applicability of section 2(22)(e) to the loan amounts received by the assessee from the other group companies, but a conscious decision was also taken by him in view the legal position as propounded by the Jurisdictional HC - revision set aside
Revision u/s 263 - lack of enquiry - Deemed dividend u/s 2(22)(e) - AO had not only made the enquiry or verification to ascertain the applicability of section 2(22)(e) to the loan amounts received by the assessee from the other group companies, but a conscious decision was also taken by him in view the legal position as propounded by the Jurisdictional HC - revision set aside
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