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 ...
Levy of penalty u/s 271AAA - Defective notice - the Assessing Officer has not confronted the assessee to substantiate the manner in which the additional income was earned in the absence of such query. It cannot be inferred that the assessee failed to substantiate the manner which additional income was earned - Penalty deleted - AT
Levy of penalty u/s 271AAA - Defective notice - the Assessing Officer has not confronted the assessee to substantiate the manner in which the additional income was earned in the absence of such query. It cannot be inferred that the assessee failed to substantiate the manner which additional income was earned - Penalty deleted - AT
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