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 partly allowed the assessee's appeal. Travel expenses were partly disallowed by 30% considering personal element, while 70% were allowed as business expenses due to lack of documentary evidence establishing exclusive business purpose. Unexplained cash credits u/s 68 were confirmed as the assessee failed to prove identity, creditworthiness, and genuineness of transactions. Disallowance u/s 36(1)(va) for delayed PF/ESIC contributions was upheld following jurisdictional High Court's decision. However, disallowance u/s 36(1)(iii) for interest was deleted as the assessee demonstrated availability of sufficient interest-free funds.
The ITAT partly allowed the assessee's appeal. Travel expenses were partly disallowed by 30% considering personal element, while 70% were allowed as business expenses due to lack of documentary evidence establishing exclusive business purpose. Unexplained cash credits u/s 68 were confirmed as the assessee failed to prove identity, creditworthiness, and genuineness of transactions. Disallowance u/s 36(1)(va) for delayed PF/ESIC contributions was upheld following jurisdictional High Court's decision. However, disallowance u/s 36(1)(iii) for interest was deleted as the assessee demonstrated availability of sufficient interest-free funds.
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