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 ...
Penalty levied u/s.271(1)(c) - concealment of income - the conclusion of the AO that amount was not finding mention in the regular books of accounts is over-sweeping over statement, because the fact remains that the books of accounts were not “closed”, then as the year was yet not over - The year in the case of the assessee being the first year of operation, it cannot even be implied that that the amount pertained to earlier year(s) of its business. - No penalty.
Penalty levied u/s.271(1)(c) - concealment of income - the conclusion of the AO that amount was not finding mention in the regular books of accounts is over-sweeping over statement, because the fact remains that the books of accounts were not “closed”, then as the year was yet not over - The year in the case of the assessee being the first year of operation, it cannot even be implied that that the amount pertained to earlier year(s) of its business. - No penalty.
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