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 ...
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Capital gain computation - Exemption u/s 54 - The claim of the assessee is supported by the agreement, receipt and name appearing in the bank statement of the contractor. CIT(A) merely stated his comments and there is no controverted finding on the documents in the remand report and the contentions raised by the CIT(A) were not verified by the ld. AO nor the finding is appearing in the order of the CIT(A) that the ld. AO has commented on these documents. The assessee was not given an opportunity to refuted these allegations so made. - Claim of the assessee for an amount cannot be disbelieved - AT
Capital gain computation - Exemption u/s 54 - The claim of the assessee is supported by the agreement, receipt and name appearing in the bank statement of the contractor. CIT(A) merely stated his comments and there is no controverted finding on the documents in the remand report and the contentions raised by the CIT(A) were not verified by the ld. AO nor the finding is appearing in the order of the CIT(A) that the ld. AO has commented on these documents. The assessee was not given an opportunity to refuted these allegations so made. - Claim of the assessee for an amount cannot be disbelieved - AT
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