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 ...
Addition u/s 56(2)(vii)(b) - transfer under gift deed - family settlement- The Assessee contended that the transfer of land through a gift deed was part of a family settlement/arrangement between the parties involved. They argued that various documents, including a family settlement arrangement and MOUs, supported their position. The Revenue, however, maintained that the transfer was without consideration and fell within the ambit of deemed income under the Act. - The ITAT concluded that the transaction should be understood in the context of the broader arrangement and not in isolation. Therefore, the addition made by the AO was deemed unjustified, and the appeal of the Assessee was allowed.
Addition u/s 56(2)(vii)(b) - transfer under gift deed - family settlement- The Assessee contended that the transfer of land through a gift deed was part of a family settlement/arrangement between the parties involved. They argued that various documents, including a family settlement arrangement and MOUs, supported their position. The Revenue, however, maintained that the transfer was without consideration and fell within the ambit of deemed income under the Act. - The ITAT concluded that the transaction should be understood in the context of the broader arrangement and not in isolation. Therefore, the addition made by the AO was deemed unjustified, and the appeal of the Assessee was allowed.
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