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 ...
Assessment u/s 153C - Undisclosed investment u/s 69 r.w.s 115BBE - Whether incriminating material belonging to Assessee found during the course of search on the basis of which addition is made? - The Tribunal dissected the allegations and defenses, scrutinizing the legitimacy of the seized documents, their relation to the assessee, and the actual value of the property in question. The tribunal was tasked with determining whether the documents held any credence in proving undisclosed investments by the assessee and if the procedural aspects under the IT Act were duly followed. - The Tribunal favored the assessee's arguments, highlighting the lack of concrete evidence linking the seized documents to undisclosed investments directly attributable to the assessee. It questioned the AO's reliance on circumstantial evidence without substantiating the actual transaction amount or proving the assessee's involvement beyond reasonable doubt.
Assessment u/s 153C - Undisclosed investment u/s 69 r.w.s 115BBE - Whether incriminating material belonging to Assessee found during the course of search on the basis of which addition is made? - The Tribunal dissected the allegations and defenses, scrutinizing the legitimacy of the seized documents, their relation to the assessee, and the actual value of the property in question. The tribunal was tasked with determining whether the documents held any credence in proving undisclosed investments by the assessee and if the procedural aspects under the IT Act were duly followed. - The Tribunal favored the assessee's arguments, highlighting the lack of concrete evidence linking the seized documents to undisclosed investments directly attributable to the assessee. It questioned the AO's reliance on circumstantial evidence without substantiating the actual transaction amount or proving the assessee's involvement beyond reasonable doubt.
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