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 ...
The ITAT Delhi held that the addition for unexplained investment made to a company was unjustified. The Tribunal found that the total investments were made through a banking channel, specifically after withdrawals from an Axis Bank Account. The source of deposits in the account was explained and admitted, making the addition on account of withdrawals irrational. The addition from an undisclosed source related to a bridal business was based on suspicion, with the AO and CIT(A) erroneously holding 30% of deposits. The Tribunal considered the nature of the business and calculated the security amount at 10% of the hire charges. The assessee satisfactorily explained the bank entries, leading to the appeal being allowed due to a miscarriage of justice.
The ITAT Delhi held that the addition for unexplained investment made to a company was unjustified. The Tribunal found that the total investments were made through a banking channel, specifically after withdrawals from an Axis Bank Account. The source of deposits in the account was explained and admitted, making the addition on account of withdrawals irrational. The addition from an undisclosed source related to a bridal business was based on suspicion, with the AO and CIT(A) erroneously holding 30% of deposits. The Tribunal considered the nature of the business and calculated the security amount at 10% of the hire charges. The assessee satisfactorily explained the bank entries, leading to the appeal being allowed due to a miscarriage of justice.
Note: It is a system-generated summary and is for quick reference only.