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 by CIT - Addition u/s 68 - the transaction has never been examined by the assessing officer. No enquiry has been conducted relating to the alleged sum. - where only few cases are selected for scrutiny such type of scrutiny proceedings as has been carried out by the assessing officer are erroneous so far as they are prejudicial to the interest of the revenue wherein the important aspects and the crucial financial transactions having sufficient volume in terms of value remained to be examined by the AO. - Revision order sustained - AT
Revision u/s 263 by CIT - Addition u/s 68 - the transaction has never been examined by the assessing officer. No enquiry has been conducted relating to the alleged sum. - where only few cases are selected for scrutiny such type of scrutiny proceedings as has been carried out by the assessing officer are erroneous so far as they are prejudicial to the interest of the revenue wherein the important aspects and the crucial financial transactions having sufficient volume in terms of value remained to be examined by the AO. - Revision order sustained - AT
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