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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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Exemption u/s 11 - loss incurred out of corpus fund - What is taxable is the real income. If the AO’s view is to be accepted, it would lead to incongruous results. We say so because in the event, the assessee had earned profit in the instant transaction, the Revenue would have imposed tax on assessee. There cannot be different standards of examining facts when the assessee earns profit and when it suffers loss. - HC
Exemption u/s 11 - loss incurred out of corpus fund - What is taxable is the real income. If the AO’s view is to be accepted, it would lead to incongruous results. We say so because in the event, the assessee had earned profit in the instant transaction, the Revenue would have imposed tax on assessee. There cannot be different standards of examining facts when the assessee earns profit and when it suffers loss. - HC
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