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 - Taxability of income disclosed in survey proceedings u/s 133A at Higher Rate of tax u/s 115BBE - ITAT quashed order treating the undisclosed income as business income and not under the higher tax rate provisions of Section 115BBE. - The High court agreed with the Tribunal's finding that sufficient inquiry was made and the income was rightly treated as business income, thus, upholding the Tribunal's decision.
Revision u/s 263 - Taxability of income disclosed in survey proceedings u/s 133A at Higher Rate of tax u/s 115BBE - ITAT quashed order treating the undisclosed income as business income and not under the higher tax rate provisions of Section 115BBE. - The High court agreed with the Tribunal's finding that sufficient inquiry was made and the income was rightly treated as business income, thus, upholding the Tribunal's decision.
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