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 ...
Section 69A addition for unexplained income treated as advances was rightly deleted as the loan amounts were recorded in books, supported by bank statements and confirmations, even if details of immovable property transaction were unavailable. The assessee was not the owner of unrecorded assets, satisfying Section 69A conditions. CIT(A) rightly deleted the addition after considering all aspects. Addition of Rs. 1.70 crores relating to Outstripe Suppliers Pvt. Ltd. transaction was part of Rs. 2 crores addition for the same transaction in the previous year, leading to double addition, hence rightly deleted by CIT(A).
Section 69A addition for unexplained income treated as advances was rightly deleted as the loan amounts were recorded in books, supported by bank statements and confirmations, even if details of immovable property transaction were unavailable. The assessee was not the owner of unrecorded assets, satisfying Section 69A conditions. CIT(A) rightly deleted the addition after considering all aspects. Addition of Rs. 1.70 crores relating to Outstripe Suppliers Pvt. Ltd. transaction was part of Rs. 2 crores addition for the same transaction in the previous year, leading to double addition, hence rightly deleted by CIT(A).
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