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 held that a reasonable gross profit rate of 2% should be applied on unaccounted purchases of gold, instead of the AO's net profit rate of 12%. The disallowance u/s 40A(3) was deleted as the income was assessed applying the flat gross profit rate. The addition for excess stock jewellery was set aside and remanded to the AO for fresh adjudication after verifying the invoices filed by the assessee.
The ITAT held that a reasonable gross profit rate of 2% should be applied on unaccounted purchases of gold, instead of the AO's net profit rate of 12%. The disallowance u/s 40A(3) was deleted as the income was assessed applying the flat gross profit rate. The addition for excess stock jewellery was set aside and remanded to the AO for fresh adjudication after verifying the invoices filed by the assessee.
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