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 ...
Levy of penalty u/s. 271(1)(c) - The appellant contended that the addition made by the Assessing Officer was based solely on estimations, making it ineligible for penalty imposition. The ITAT upheld this argument, citing legal precedents to support its decision. Additionally, the court noted the defective nature of the penalty notice issued by the Assessing Officer, further bolstering the appellant's case. - Consequently, the Tribunal set aside the impugned order and allowed the appellant's appeal, directing the deletion of the penalty.
Levy of penalty u/s. 271(1)(c) - The appellant contended that the addition made by the Assessing Officer was based solely on estimations, making it ineligible for penalty imposition. The ITAT upheld this argument, citing legal precedents to support its decision. Additionally, the court noted the defective nature of the penalty notice issued by the Assessing Officer, further bolstering the appellant's case. - Consequently, the Tribunal set aside the impugned order and allowed the appellant's appeal, directing the deletion of the penalty.
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