Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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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 u/s 69 - addition based on the estimation of the cost of acquisition of the property - The ITAT observed that the AO had relied heavily on statements obtained during the survey proceedings, particularly regarding the payment of on-money for the property purchase. However, the Tribunal emphasized that such statements, which were later retracted, could not constitute valid evidence for making additions to the appellant's income. Furthermore, the Tribunal noted that the AO had not provided any supporting material apart from these statements to justify the addition. Considering these factors, the Tribunal held that the AO's decision to estimate the property acquisition cost at a higher value lacked sufficient basis and was not supported by credible evidence.
Addition u/s 69 - addition based on the estimation of the cost of acquisition of the property - The ITAT observed that the AO had relied heavily on statements obtained during the survey proceedings, particularly regarding the payment of on-money for the property purchase. However, the Tribunal emphasized that such statements, which were later retracted, could not constitute valid evidence for making additions to the appellant's income. Furthermore, the Tribunal noted that the AO had not provided any supporting material apart from these statements to justify the addition. Considering these factors, the Tribunal held that the AO's decision to estimate the property acquisition cost at a higher value lacked sufficient basis and was not supported by credible evidence.
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