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 ...
Penalty u/s 270A - misreporting of the income - disallowances of 40A(3) on account of interest income in the other sources and has also disallowed the claim of the assessee u/s 32 disputing the period use of the asset of the assessee - The Tribunal emphasized the distinction between assessment and penalty proceedings and noted that the mere addition in assessment did not automatically imply concealment. The ITAT also highlighted the appellant's compliance with depositing the demand within the stipulated time frame, albeit the procedural lapse in filing Form No. 68. Ultimately, the Tribunal ruled in favor of the appellant, directing the deletion of the penalty levied under section 270A of the Act.
Penalty u/s 270A - misreporting of the income - disallowances of 40A(3) on account of interest income in the other sources and has also disallowed the claim of the assessee u/s 32 disputing the period use of the asset of the assessee - The Tribunal emphasized the distinction between assessment and penalty proceedings and noted that the mere addition in assessment did not automatically imply concealment. The ITAT also highlighted the appellant's compliance with depositing the demand within the stipulated time frame, albeit the procedural lapse in filing Form No. 68. Ultimately, the Tribunal ruled in favor of the appellant, directing the deletion of the penalty levied under section 270A of the Act.
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