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...
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Penalty levied u/s 271D - assessee has availed cash loan in contravention of provision of section 269SS - Assessee has submitted that though the assessee has initially availed loans from close relatives, which were subsequently the loans, were treated as gift and credited to his capital account, therefore, levy of penalty under section 271D of the Act is unwarranted - The Tribunal found the explanations offered by the appellant reasonable, especially considering the confirmation letters from the lenders, and the circumstances surrounding the transactions. Accordingly, ITAT directed the AO to delete the penalty.
Penalty levied u/s 271D - assessee has availed cash loan in contravention of provision of section 269SS - Assessee has submitted that though the assessee has initially availed loans from close relatives, which were subsequently the loans, were treated as gift and credited to his capital account, therefore, levy of penalty under section 271D of the Act is unwarranted - The Tribunal found the explanations offered by the appellant reasonable, especially considering the confirmation letters from the lenders, and the circumstances surrounding the transactions. Accordingly, ITAT directed the AO to delete the penalty.
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