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 u/s 271(1)(c) - disallowances in the quantum assessment order - whether any concealment or furnishing of inaccurate particulars proved? - Tribunal directs deletion of penalty concerning disallowance under section 40(a)(ia) as the quantum appeal resulted in deletion of the addition. - Penalty in relation to unexplained investment and capital expenditure is remanded to the Commissioner of Income Tax (Appeals) for reconsideration post-quantum appeal decision. - Tribunal upholds penalty on foreign traveling expenses and commission payments, citing lack of evidence to establish business purpose or compliance with tax regulations.
Penalty u/s 271(1)(c) - disallowances in the quantum assessment order - whether any concealment or furnishing of inaccurate particulars proved? - Tribunal directs deletion of penalty concerning disallowance under section 40(a)(ia) as the quantum appeal resulted in deletion of the addition. - Penalty in relation to unexplained investment and capital expenditure is remanded to the Commissioner of Income Tax (Appeals) for reconsideration post-quantum appeal decision. - Tribunal upholds penalty on foreign traveling expenses and commission payments, citing lack of evidence to establish business purpose or compliance with tax regulations.
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