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...
Validity of Revision u/s 263 - The tribunal held that the exercise of the second revision jurisdiction by the PCIT on the same issue was not justified. It noted that the AO had made necessary inquiries as per the directions of the first PCIT and that the assessee had provided sufficient evidence to prove the identity, creditworthiness, and genuineness of the share subscribers.
Validity of Revision u/s 263 - The tribunal held that the exercise of the second revision jurisdiction by the PCIT on the same issue was not justified. It noted that the AO had made necessary inquiries as per the directions of the first PCIT and that the assessee had provided sufficient evidence to prove the identity, creditworthiness, and genuineness of the share subscribers.
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