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 ...
Assessment u/s 153A - unexplained investment in Hotel Building - addition under sec 69 r.w.s. 115BBE - reliance on DVO report post-search - Held, DVO report estimation-based, no incriminating material found during search, addition not valid. Rejection of books u/s 145(3) - difference in investment amount, books not rejected due to deletion of difference. Disallowance of current year business loss - unjustified due to sustainable books rejection. Disallowance u/s 35AD - hotel building expenditure - 4-star rating obtained, qualifies for deduction, AO's misinterpretation rejected, claim allowed.
Assessment u/s 153A - unexplained investment in Hotel Building - addition under sec 69 r.w.s. 115BBE - reliance on DVO report post-search - Held, DVO report estimation-based, no incriminating material found during search, addition not valid. Rejection of books u/s 145(3) - difference in investment amount, books not rejected due to deletion of difference. Disallowance of current year business loss - unjustified due to sustainable books rejection. Disallowance u/s 35AD - hotel building expenditure - 4-star rating obtained, qualifies for deduction, AO's misinterpretation rejected, claim allowed.
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