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 ...
Rectification u/s 154 - under-assessment of income qua the foregoing depreciation/additional depreciation issue(s) - The Tribunal considered the Revenue’s contentions but found no merit in them. It was observed that the rectification proceedings under section 154 initiated by the Assessing Officer were not sustainable, as they involved a detailed re-computation of the assessee’s depreciation claims, which went beyond rectifying apparent mistakes on record. - In light of the decision of Supreme Court, the Tribunal dismissed the Revenue’s appeal, affirming the CIT(A)’s decision.
Rectification u/s 154 - under-assessment of income qua the foregoing depreciation/additional depreciation issue(s) - The Tribunal considered the Revenue’s contentions but found no merit in them. It was observed that the rectification proceedings under section 154 initiated by the Assessing Officer were not sustainable, as they involved a detailed re-computation of the assessee’s depreciation claims, which went beyond rectifying apparent mistakes on record. - In light of the decision of Supreme Court, the Tribunal dismissed the Revenue’s appeal, affirming the CIT(A)’s decision.
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