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...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Exemption u/s 11(1)(a) and Section 11(2) for Deemed income u/s 11(3) - Assessee would be allowed to accumulate the income if there is “real income” which is in possession of the assessee - something which is not in possession of the assessee cannot be accumulated or utilized at a later date. - Therefore “deemed income” u/s 11(3) of the Act is not eligible for claim of exemption under Section 11(1)(a) and Section 11(2) of the Act. - AT
Exemption u/s 11(1)(a) and Section 11(2) for Deemed income u/s 11(3) - Assessee would be allowed to accumulate the income if there is “real income” which is in possession of the assessee - something which is not in possession of the assessee cannot be accumulated or utilized at a later date. - Therefore “deemed income” u/s 11(3) of the Act is not eligible for claim of exemption under Section 11(1)(a) and Section 11(2) of the Act. - AT
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