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 ...
Unexplained expenditure u/s 69C - genuineness of purchases - Assessee statedly had made purchases from the three parties - Payments made through banking channels - Assessee in our view has discharged his onus in respect of the subject purchases. AO has also not doubted the sales arising out of the said export activity and its GPR. This is not a case which falls within the ambit of Section 69C as held by the AO. - HC
Unexplained expenditure u/s 69C - genuineness of purchases - Assessee statedly had made purchases from the three parties - Payments made through banking channels - Assessee in our view has discharged his onus in respect of the subject purchases. AO has also not doubted the sales arising out of the said export activity and its GPR. This is not a case which falls within the ambit of Section 69C as held by the AO. - HC
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