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...
The case concerns disallowance u/s 14A r.w.r. 8D without exempt income for A.Y. Issue of retrospective/prospective application of Section 14A explanation post Finance Act, 2022. CIT(A) upheld disallowance citing Finance Act, 2020. SC rulings state disallowance impermissible without exempt income. AO's presumptions on investment source are not legally tenable. CIT(A)'s reliance on retrospective application of Section 14A explanation is illegal. Section 14A amendment not retroactive to A.Y. 2016-17. Tribunal rules against revenue, in favor of appellant, as AO's satisfaction for disallowance was based on future dividend income presumptions, lacking legal basis.
The case concerns disallowance u/s 14A r.w.r. 8D without exempt income for A.Y. Issue of retrospective/prospective application of Section 14A explanation post Finance Act, 2022. CIT(A) upheld disallowance citing Finance Act, 2020. SC rulings state disallowance impermissible without exempt income. AO's presumptions on investment source are not legally tenable. CIT(A)'s reliance on retrospective application of Section 14A explanation is illegal. Section 14A amendment not retroactive to A.Y. 2016-17. Tribunal rules against revenue, in favor of appellant, as AO's satisfaction for disallowance was based on future dividend income presumptions, lacking legal basis.
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