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...
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Power of Tribunal for enhancement - The AO at no point of time, disputed the date on which the business of the assessee was set up but disputed allowability of certain expenses on ground that assessee not commenced its commercial activity - Tribunal has no jurisdiction in venturing into an issue which was never an issue before the AO and cannot take away the benefit given to the assessee by the AO
Power of Tribunal for enhancement - The AO at no point of time, disputed the date on which the business of the assessee was set up but disputed allowability of certain expenses on ground that assessee not commenced its commercial activity - Tribunal has no jurisdiction in venturing into an issue which was never an issue before the AO and cannot take away the benefit given to the assessee by the AO
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