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...
Estimated income from sale of plots- In this case, except agreement to sale for one plot, the AO does not have any other credible evidence to support his estimation of income by extrapolation of rate on the basis of agreement to sale for one plot to remaining plots sold during the block period. In our considered view, the estimation made by the AO towards undisclosed income of under reporting of sales Revenue from sale of plots, is purely a guess work, which is based on the suspicion and surmises, but not based on any material evidences. - AT
Estimated income from sale of plots- In this case, except agreement to sale for one plot, the AO does not have any other credible evidence to support his estimation of income by extrapolation of rate on the basis of agreement to sale for one plot to remaining plots sold during the block period. In our considered view, the estimation made by the AO towards undisclosed income of under reporting of sales Revenue from sale of plots, is purely a guess work, which is based on the suspicion and surmises, but not based on any material evidences. - AT
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