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 ...
Rectification u/s 154 - Characterization of receipts - Exemption of interest on enhanced compensation from tax denied u/s. 10(37) - However, the Appellate Tribunal dismissed the appeal, affirming the Assessing Officer's decision to tax 50% of the interest. The Tribunal held that the interest did not fall under section 28 of the LAA and was taxable as income. The plea for rectification under section 154 was rejected as there was no mistake in the assessment order.
Rectification u/s 154 - Characterization of receipts - Exemption of interest on enhanced compensation from tax denied u/s. 10(37) - However, the Appellate Tribunal dismissed the appeal, affirming the Assessing Officer's decision to tax 50% of the interest. The Tribunal held that the interest did not fall under section 28 of the LAA and was taxable as income. The plea for rectification under section 154 was rejected as there was no mistake in the assessment order.
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