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 ...
Penalty levied u/s 271(1)(c) - addition u/s 2(22)(e) - deemed dividend - While levying the penalty, the deeming provisions can be applied to a limited extent and instant case was concerned with the imposition of penalty under section 271(1)(c), which was not sustainable in so far as the assessee-company was not a registered shareholder of loan advancing company who had vien loan / advance to the assessee-company. - AT
Penalty levied u/s 271(1)(c) - addition u/s 2(22)(e) - deemed dividend - While levying the penalty, the deeming provisions can be applied to a limited extent and instant case was concerned with the imposition of penalty under section 271(1)(c), which was not sustainable in so far as the assessee-company was not a registered shareholder of loan advancing company who had vien loan / advance to the assessee-company. - AT
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