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 ...
Rectification u/s 154 - claim the allowance of 50% of the expenses against the commission income - Since the assessee has himself not pressed the issue as to allowability of 50% of the expenses against the income earned in the original appeal filed before the Tribunal vide appeal for for A.Y. 2004-05 to A.Y 2010-11 decided against which miscellaneous application has also been dismissed, he is not entitled to re-agitate the same issue before the Tribuanl under the garb of filing application under section 154 of the Act before the AO and then filling the appeal before the Ld. CIT(A) and the Tribunal. - AT
Rectification u/s 154 - claim the allowance of 50% of the expenses against the commission income - Since the assessee has himself not pressed the issue as to allowability of 50% of the expenses against the income earned in the original appeal filed before the Tribunal vide appeal for for A.Y. 2004-05 to A.Y 2010-11 decided against which miscellaneous application has also been dismissed, he is not entitled to re-agitate the same issue before the Tribuanl under the garb of filing application under section 154 of the Act before the AO and then filling the appeal before the Ld. CIT(A) and the Tribunal. - AT
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