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 ...
The ITAT upheld the revision order u/s 263 The PCIT demonstrated that the Assessing Officer failed to examine/inquire/investigate transactions in the demat account, bank account, and receipts as per Form 26AS vis-`a-vis the Income Tax Return, despite being required to conduct adequate examinations/inquiries/investigations to arrive at a logical conclusion. The assessee did not rebut the PCIT's finding or provide evidence of the AO examining these issues. Consequently, the Tribunal ruled that the PCIT rightly exercised jurisdiction u/s 263, and the decision went against the assessee.
The ITAT upheld the revision order u/s 263 The PCIT demonstrated that the Assessing Officer failed to examine/inquire/investigate transactions in the demat account, bank account, and receipts as per Form 26AS vis-`a-vis the Income Tax Return, despite being required to conduct adequate examinations/inquiries/investigations to arrive at a logical conclusion. The assessee did not rebut the PCIT's finding or provide evidence of the AO examining these issues. Consequently, the Tribunal ruled that the PCIT rightly exercised jurisdiction u/s 263, and the decision went against the assessee.
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