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 ...
Revision u/s 263 - The revenue is disputing on non conduct of enquiry, but we find the assessee firm has discharged its burden of proof on submitting the vital requisite details called for by the assessing officer by issue of statutory notice U/sec 142(1) of the Act along with the questioner which cannot be over looked. Since the information was available with the A.O in the course of the assessment, the A.O. has considered the facts, submissions and evidences filed and took a view. - AT
Revision u/s 263 - The revenue is disputing on non conduct of enquiry, but we find the assessee firm has discharged its burden of proof on submitting the vital requisite details called for by the assessing officer by issue of statutory notice U/sec 142(1) of the Act along with the questioner which cannot be over looked. Since the information was available with the A.O in the course of the assessment, the A.O. has considered the facts, submissions and evidences filed and took a view. - AT
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