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 once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
The ITAT held that once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
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