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 ...
Disallowance based on third party information about unexplained purchases was challenged. ITAT held that the additions were unsustainable as the disallowance was solely based on unverified third-party information gathered by the Department's Investigation Wing, without providing an opportunity for cross-examination to the assessee, who had prima facie substantiated the purchases through documentation like bills, confirmed accounts, and VAT registration of sellers. The purchases were found acceptable, and the consequent addition to income was directed to be deleted, favoring the assessee.
Disallowance based on third party information about unexplained purchases was challenged. ITAT held that the additions were unsustainable as the disallowance was solely based on unverified third-party information gathered by the Department's Investigation Wing, without providing an opportunity for cross-examination to the assessee, who had prima facie substantiated the purchases through documentation like bills, confirmed accounts, and VAT registration of sellers. The purchases were found acceptable, and the consequent addition to income was directed to be deleted, favoring the assessee.
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