Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
An allotment letter from a developer is considered an agreement to purchase a property, and payments made through banking channels establish its veracity. The valuation date for determining any deemed gift is the date of the first payment, not the later date of property transfer. CBDT circulars recognize allotment letters as agreements for construction, granting capital gains set-off benefits to purchasers. Applying this analogy, the assessee's allotment letter and cheque payments from June 2010 constitute an agreement, precluding additions u/s 56(2)(vii)(b)(ii) for deemed gifts. The Assessing Officer erred in considering the valuation date as October 2014, and the addition is deleted by the Appellate Tribunal.
An allotment letter from a developer is considered an agreement to purchase a property, and payments made through banking channels establish its veracity. The valuation date for determining any deemed gift is the date of the first payment, not the later date of property transfer. CBDT circulars recognize allotment letters as agreements for construction, granting capital gains set-off benefits to purchasers. Applying this analogy, the assessee's allotment letter and cheque payments from June 2010 constitute an agreement, precluding additions u/s 56(2)(vii)(b)(ii) for deemed gifts. The Assessing Officer erred in considering the valuation date as October 2014, and the addition is deleted by the Appellate Tribunal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
