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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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Assessment u/s 153A - Unexplained investment in hotel construction rejected as the material found during search pertained to another person, not the assessee. CIT(A) had rightly deleted the addition, as income from such investment is assessable in the hands of the partnership firm. Undisclosed income from Garden Mahaveer Paradise - CIT(A) order upholding deletion of addition affirmed after examining assessment order, documents, and submissions. Unexplained investment u/s 69 for residential property - Assessee engaged in construction material business, utilized contacts to reduce costs by 10%. No discrepancy pointed out in registered valuer's report. AO made addition without considering objections. CIT(A) allowed assessee's ground based on assessment order, documents, and reasoned order. Scope of incriminating documents - Only incriminating material, not merely material, can be considered for unabated assessments. No incriminating material found during search, only declared construction bills. CIT(A) rightly allowed assessee's appeal after examining all aspects.
Assessment u/s 153A - Unexplained investment in hotel construction rejected as the material found during search pertained to another person, not the assessee. CIT(A) had rightly deleted the addition, as income from such investment is assessable in the hands of the partnership firm. Undisclosed income from Garden Mahaveer Paradise - CIT(A) order upholding deletion of addition affirmed after examining assessment order, documents, and submissions. Unexplained investment u/s 69 for residential property - Assessee engaged in construction material business, utilized contacts to reduce costs by 10%. No discrepancy pointed out in registered valuer's report. AO made addition without considering objections. CIT(A) allowed assessee's ground based on assessment order, documents, and reasoned order. Scope of incriminating documents - Only incriminating material, not merely material, can be considered for unabated assessments. No incriminating material found during search, only declared construction bills. CIT(A) rightly allowed assessee's appeal after examining all aspects.
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