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 ...
Addition of opening capital as unexplained investment u/s 69 - income from undisclosed sources - The Tribunal held that for such an addition to be justified, the Assessing Officer must provide a concrete rationale for not accepting the disclosed sources of income, which was not done in this case. This decision reinforces the principle that tax authorities must adhere to strict standards of evidence and rationale when alleging undisclosed income.
Addition of opening capital as unexplained investment u/s 69 - income from undisclosed sources - The Tribunal held that for such an addition to be justified, the Assessing Officer must provide a concrete rationale for not accepting the disclosed sources of income, which was not done in this case. This decision reinforces the principle that tax authorities must adhere to strict standards of evidence and rationale when alleging undisclosed income.
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