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 addressed various issues in the case. Firstly, regarding addition u/s 68 due to a difference in Form 26AS and income in the return, CIT(A) deleted the addition as the amount was already accounted for in a previous assessment year, attributing the discrepancy to an error by M/s Dharampal Satyapal Ltd. The Tribunal upheld this decision based on reconciliation presented. Secondly, disallowance u/s 37 on salary/wages was challenged, but CIT(A) found evidence of proper payments to employees and deleted the addition. Lastly, disallowance u/s 14A was not warranted as no exempt income was earned by the assessee, following the precedent set in Cheminvest Limited case.
The ITAT Delhi addressed various issues in the case. Firstly, regarding addition u/s 68 due to a difference in Form 26AS and income in the return, CIT(A) deleted the addition as the amount was already accounted for in a previous assessment year, attributing the discrepancy to an error by M/s Dharampal Satyapal Ltd. The Tribunal upheld this decision based on reconciliation presented. Secondly, disallowance u/s 37 on salary/wages was challenged, but CIT(A) found evidence of proper payments to employees and deleted the addition. Lastly, disallowance u/s 14A was not warranted as no exempt income was earned by the assessee, following the precedent set in Cheminvest Limited case.
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