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 ...
Assessee maintained separate books of accounts and furnished audited financial statements for each eligible infrastructure project, fulfilling conditions for deduction u/s 80IA. CIT(A) rightly allowed deduction, following precedent. Unverified credit balances cannot be added as payments were made through cheques and reflected in books. Ad hoc disallowances of expenses and wages deleted by CIT(A) based on Tribunal decisions. TDS u/s 194H not deducted on petty commission payments below Rs. 5,000, rightly deleted by CIT(A). Assessee opted for Vivad se Vishwas Scheme, paid identified tax, eligible for refund. Cross-objection withdrawn with liberty to restore if dispute not settled under scheme. No interference warranted in CIT(A)'s well-reasoned order.
Assessee maintained separate books of accounts and furnished audited financial statements for each eligible infrastructure project, fulfilling conditions for deduction u/s 80IA. CIT(A) rightly allowed deduction, following precedent. Unverified credit balances cannot be added as payments were made through cheques and reflected in books. Ad hoc disallowances of expenses and wages deleted by CIT(A) based on Tribunal decisions. TDS u/s 194H not deducted on petty commission payments below Rs. 5,000, rightly deleted by CIT(A). Assessee opted for Vivad se Vishwas Scheme, paid identified tax, eligible for refund. Cross-objection withdrawn with liberty to restore if dispute not settled under scheme. No interference warranted in CIT(A)'s well-reasoned order.
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