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 ...
Addition based on retracted statement recorded on oath u/s 132(4)/133A - Statement taken even u/s 132(4) of the Act cannot be used as conclusive evidence if it is not backed by credible evidence - AO not having any fresh information/material in his possession, merely on retracted statement formed his belief about escapement of income which is not sustainable in law. - AT
Addition based on retracted statement recorded on oath u/s 132(4)/133A - Statement taken even u/s 132(4) of the Act cannot be used as conclusive evidence if it is not backed by credible evidence - AO not having any fresh information/material in his possession, merely on retracted statement formed his belief about escapement of income which is not sustainable in law. - AT
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