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 ...
Profits arising on sale of land - ‘business income’ OR 'capital gains' - after purchase of land assessee got if converted to NA land - the assessee also got a lay out plan approved from competent authority initially for plotting of land and subsequently to build the residential blocks with small business centre in the intervening period. The facts and circumstances of such sequential events give rise to an infallible impression that the driving force for purchase of land was to exploit it commercially. - AT
Profits arising on sale of land - ‘business income’ OR 'capital gains' - after purchase of land assessee got if converted to NA land - the assessee also got a lay out plan approved from competent authority initially for plotting of land and subsequently to build the residential blocks with small business centre in the intervening period. The facts and circumstances of such sequential events give rise to an infallible impression that the driving force for purchase of land was to exploit it commercially. - AT
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