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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Addition made towards excess physical stock during the survey - unexplained investment u/s 69 taxable at rates prescribed u/s 115BBE - The ITAT concurred with the Commissioner's decision, stating that the Assessing Officer failed to rebut the assessee's valuation adjustments adequately. They agreed that the discrepancy in stock could be attributed to unrecorded sales, and upheld the Commissioner's decision to treat the addition as business income. - The ITAT dismissed the Revenue's appeal, affirming the Commissioner's order deleting the additions.
Addition made towards excess physical stock during the survey - unexplained investment u/s 69 taxable at rates prescribed u/s 115BBE - The ITAT concurred with the Commissioner's decision, stating that the Assessing Officer failed to rebut the assessee's valuation adjustments adequately. They agreed that the discrepancy in stock could be attributed to unrecorded sales, and upheld the Commissioner's decision to treat the addition as business income. - The ITAT dismissed the Revenue's appeal, affirming the Commissioner's order deleting the additions.
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