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 ...
Disallowance u/s 14A - CIT(A) deleted the suomotu disallowance made by the assessee and upheld by ITAT - claim that an income not taxable is wrongly offered for tax will not operate as any kind of estoppel against the assessee regardless whether the revised return was filed or not - Revenue is obliged to assess the correct income - suomotu disallowance correctly deleted
Disallowance u/s 14A - CIT(A) deleted the suomotu disallowance made by the assessee and upheld by ITAT - claim that an income not taxable is wrongly offered for tax will not operate as any kind of estoppel against the assessee regardless whether the revised return was filed or not - Revenue is obliged to assess the correct income - suomotu disallowance correctly deleted
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