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 ...
Levy of penalty u/s 271(1)(c) - Failure to offer full amount of Interest earned on income-tax refund as taxable income - The assessee did not contest this addition, acknowledging their mistake - The assessee explained that the interest component not returned in the impugned year was returned in the succeeding year. Therefore, the penalty for concealment or furnishing inaccurate particulars of income is untenable, and it is directed to be deleted. - AT
Levy of penalty u/s 271(1)(c) - Failure to offer full amount of Interest earned on income-tax refund as taxable income - The assessee did not contest this addition, acknowledging their mistake - The assessee explained that the interest component not returned in the impugned year was returned in the succeeding year. Therefore, the penalty for concealment or furnishing inaccurate particulars of income is untenable, and it is directed to be deleted. - AT
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