Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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Addition made towards receipt Assignment of Fee - Assessee has withdrawn amount from Escrow account and utilized for its business purpose - Although, there is a timing difference between assessment year 2008-09 and 2009-10, but because there is no change in rate of tax, there is no loss to the Revenue by deferring recognition of income to assessment year 2009-10. It is also a matter of fact that the assessee has not claimed any set-off of loss against said income in the subsequent years. - AO was completely erred in taxing assignment fee for the assessment year 2008-09 - AT
Addition made towards receipt Assignment of Fee - Assessee has withdrawn amount from Escrow account and utilized for its business purpose - Although, there is a timing difference between assessment year 2008-09 and 2009-10, but because there is no change in rate of tax, there is no loss to the Revenue by deferring recognition of income to assessment year 2009-10. It is also a matter of fact that the assessee has not claimed any set-off of loss against said income in the subsequent years. - AO was completely erred in taxing assignment fee for the assessment year 2008-09 - AT
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