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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In the case, ITAT decided on two main issues: 1. Addition on account of Gold and Silver Jewellery u/s 69A: Assessee disclosed Rs. 70,00,000 as unexplained investment during search. ITAT found the disclosed gold and silver quantities reasonable based on CBDT guidelines. Assessee declared gold ornaments and silver items in HUF for deduction. ITAT directed AO to delete Rs. 28,96,104 addition. 2. Addition of cash found u/s 69A: Assessee explained Rs. 1,50,000 belonged to M/s. Sarvodaya Agrotech. AO added Rs. 3 lac cash found. CIT(A) sustained Rs. 2 lac addition, considering savings of Rs. 2 lac. ITAT found no merit in sustaining Rs. 2 lac addition, as assessee cooperated, disclosed income, and had wealth tax history. ITAT directed AO to delete the Rs. 2 lac cash addition.
In the case, ITAT decided on two main issues: 1. Addition on account of Gold and Silver Jewellery u/s 69A: Assessee disclosed Rs. 70,00,000 as unexplained investment during search. ITAT found the disclosed gold and silver quantities reasonable based on CBDT guidelines. Assessee declared gold ornaments and silver items in HUF for deduction. ITAT directed AO to delete Rs. 28,96,104 addition. 2. Addition of cash found u/s 69A: Assessee explained Rs. 1,50,000 belonged to M/s. Sarvodaya Agrotech. AO added Rs. 3 lac cash found. CIT(A) sustained Rs. 2 lac addition, considering savings of Rs. 2 lac. ITAT found no merit in sustaining Rs. 2 lac addition, as assessee cooperated, disclosed income, and had wealth tax history. ITAT directed AO to delete the Rs. 2 lac cash addition.
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