Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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The Appellate Tribunal reviewed a case involving a revision u/s 263 related to deduction u/s 80P(2)(a)(i). The AO allowed interest income from FD investments as a deduction. The Tribunal noted a previous year's treatment by AO as "income from other sources" and rejection of the deduction claim. The CIT(A) later allowed the deduction for the previous year, stating the interest income was part of operational income u/s 80P(2)(a)(i). The Tribunal found the PCIT's revision u/s 263 invalid, as the interest income was deemed part of operational income due to statutory compulsions. The Assessment Order granting the deduction was upheld, and the PCIT's order u/s 263 was quashed. The appeal by the assessee was allowed.
The Appellate Tribunal reviewed a case involving a revision u/s 263 related to deduction u/s 80P(2)(a)(i). The AO allowed interest income from FD investments as a deduction. The Tribunal noted a previous year's treatment by AO as "income from other sources" and rejection of the deduction claim. The CIT(A) later allowed the deduction for the previous year, stating the interest income was part of operational income u/s 80P(2)(a)(i). The Tribunal found the PCIT's revision u/s 263 invalid, as the interest income was deemed part of operational income due to statutory compulsions. The Assessment Order granting the deduction was upheld, and the PCIT's order u/s 263 was quashed. The appeal by the assessee was allowed.
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