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 u/s 69C - bogus purchases of diamonds - The decision emphasizes the principle that where the genuineness of purchases is in question, but corresponding sales are not disputed, only the profit element embedded in the transactions should be brought to tax. The Tribunal's ruling aligns with the principle that in cases of alleged bogus purchases, if sales are unaffected, the focus should be on taxing the profit margin rather than disallowing entire purchases. - AT
Addition u/s 69C - bogus purchases of diamonds - The decision emphasizes the principle that where the genuineness of purchases is in question, but corresponding sales are not disputed, only the profit element embedded in the transactions should be brought to tax. The Tribunal's ruling aligns with the principle that in cases of alleged bogus purchases, if sales are unaffected, the focus should be on taxing the profit margin rather than disallowing entire purchases. - AT
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