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 - onus to prove - The Pr. CIT found the assessment order erroneous and prejudicial to the revenue's interests due to inadequate verification. - The Tribunal upheld the Ld. Principal Commissioner's decision, stating that the AO had not adequately examined the sources of cash deposits nor obtained relevant details or evidence before accepting explanations. The appellant failed to provide documentary evidence supporting claims, and the AO's assessment lacked thorough inquiry.
Revision u/s 263 - unexplained cash deposits - onus to prove - The Pr. CIT found the assessment order erroneous and prejudicial to the revenue's interests due to inadequate verification. - The Tribunal upheld the Ld. Principal Commissioner's decision, stating that the AO had not adequately examined the sources of cash deposits nor obtained relevant details or evidence before accepting explanations. The appellant failed to provide documentary evidence supporting claims, and the AO's assessment lacked thorough inquiry.
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