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 - unexplained cash deposits - The tribunal rejected the notion that unexplained deposits prior to withdrawals undermined the explanation provided by the appellant. - Regarding the PCIT's assertion of the AO's mistake in not making the addition, the tribunal stated that an assessment order must be interpreted as is, without assumptions or postulations. If the AO had indeed erred, avenues for correction, such as rectification under Section 154 of the Act, were available but not utilized.
Revision u/s 263 - unexplained cash deposits - The tribunal rejected the notion that unexplained deposits prior to withdrawals undermined the explanation provided by the appellant. - Regarding the PCIT's assertion of the AO's mistake in not making the addition, the tribunal stated that an assessment order must be interpreted as is, without assumptions or postulations. If the AO had indeed erred, avenues for correction, such as rectification under Section 154 of the Act, were available but not utilized.
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