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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Bogus Purchases - Credibility of Statements - The tribunal was not convinced by the appellant's argument that the initial statements were made under duress or misinterpreted. They emphasized that the retraction came after substantial delay and seemed more like an afterthought designed to escape tax liability. - Despite the retraction, the tribunal held that the original statements admitting to bogus purchases and additional income were credible. They relied on the timing of the retraction and the specifics of the declarations made during the survey. The admissions of additional income were deemed to substantiate the reopening of assessments for the years in question. The tribunal supported the additions made to the taxable income based on these declarations.
Bogus Purchases - Credibility of Statements - The tribunal was not convinced by the appellant's argument that the initial statements were made under duress or misinterpreted. They emphasized that the retraction came after substantial delay and seemed more like an afterthought designed to escape tax liability. - Despite the retraction, the tribunal held that the original statements admitting to bogus purchases and additional income were credible. They relied on the timing of the retraction and the specifics of the declarations made during the survey. The admissions of additional income were deemed to substantiate the reopening of assessments for the years in question. The tribunal supported the additions made to the taxable income based on these declarations.
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