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...
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The Appellate Tribunal held that penalty u/s 271(1)(c) on estimated additions due to bogus purchases from hawala dealers was unjustified as the assessee failed to provide detailed information requested by the AO. The AO estimated the income at 9%, later reduced to 5% by CIT (A). The Tribunal cited similar cases where penalties were not upheld for estimated income additions. The Tribunal rejected the argument that low tax effect appeals by Revenue were invalid, stating that appeals on issues of addition and penalties based on specified information are permissible. The decision favored the assessee.
The Appellate Tribunal held that penalty u/s 271(1)(c) on estimated additions due to bogus purchases from hawala dealers was unjustified as the assessee failed to provide detailed information requested by the AO. The AO estimated the income at 9%, later reduced to 5% by CIT (A). The Tribunal cited similar cases where penalties were not upheld for estimated income additions. The Tribunal rejected the argument that low tax effect appeals by Revenue were invalid, stating that appeals on issues of addition and penalties based on specified information are permissible. The decision favored the assessee.
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