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 Mumbai upheld the disallowance made u/s. 80IA due to the assessee not claiming the deduction u/s. 80IA in response to the return filed u/s. 153A. The AO added bogus purchases, but the CIT(A) confirmed the addition while allowing deduction u/s. 80IA as the purchases were related to business activity. The AO applied gross profit rate to one party's purchases and deemed the other party's transactions as 'bogus,' leading to an increase in business income eligible for u/s. 80IA deduction. The ITAT relied on CBDT Circular No.37 of 2016 and past precedents, affirming the CIT(A)'s decision. The appeal was decided against the revenue.
The ITAT Mumbai upheld the disallowance made u/s. 80IA due to the assessee not claiming the deduction u/s. 80IA in response to the return filed u/s. 153A. The AO added bogus purchases, but the CIT(A) confirmed the addition while allowing deduction u/s. 80IA as the purchases were related to business activity. The AO applied gross profit rate to one party's purchases and deemed the other party's transactions as 'bogus,' leading to an increase in business income eligible for u/s. 80IA deduction. The ITAT relied on CBDT Circular No.37 of 2016 and past precedents, affirming the CIT(A)'s decision. The appeal was decided against the revenue.
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