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 ...
Revision u/s 263 - large share premium received - valuation of shares and the applicability of Section 56(2)(viib) - The Tribunal found that the PCIT's order was erroneous as it did not properly consider the assessee's provided documentation and valuation report under Rule 11UA of the Income Tax Rules. The Tribunal concluded that the original assessment order by the Assessing Officer (AO) was not erroneous, and thus, the exercise of power u/s 263 by the PCIT was incorrect.
Revision u/s 263 - large share premium received - valuation of shares and the applicability of Section 56(2)(viib) - The Tribunal found that the PCIT's order was erroneous as it did not properly consider the assessee's provided documentation and valuation report under Rule 11UA of the Income Tax Rules. The Tribunal concluded that the original assessment order by the Assessing Officer (AO) was not erroneous, and thus, the exercise of power u/s 263 by the PCIT was incorrect.
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