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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Protective addition on account of unexplained credit entries appearing in the bank account - assessee company is a conduit - addition on account of unaccounted commission @ 0.25 % of total unexplained credit entries - The CIT(A) had deleted these additions, finding that the assessee acted as a conduit for accommodation entries, with identified beneficiaries, thus no further addition was warranted in the assessee's hands. The ITAT upheld the CIT(A)'s decision, noting that since the assessee operated as a conduit managed by certain individuals for providing accommodation entries, no addition for commission income was justified.
Protective addition on account of unexplained credit entries appearing in the bank account - assessee company is a conduit - addition on account of unaccounted commission @ 0.25 % of total unexplained credit entries - The CIT(A) had deleted these additions, finding that the assessee acted as a conduit for accommodation entries, with identified beneficiaries, thus no further addition was warranted in the assessee's hands. The ITAT upheld the CIT(A)'s decision, noting that since the assessee operated as a conduit managed by certain individuals for providing accommodation entries, no addition for commission income was justified.
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