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 ...
ITAT reversed CIT(A)'s addition under s.69 regarding unexplained property investment, accepting loan from assessee's mother as legitimate source after verification of her creditworthiness in reopened assessment. On interest disallowance under s.24, ITAT directed AO to verify if assessee's investment from borrowed funds was limited to their ownership share. Interest deduction permitted only on borrowed funds used for initial property investment up to assessee's share portion, following prudent investment principle. Subsequent investments, even if from borrowed funds, deemed ineligible for s.24 interest deduction. Matter remanded to AO for verification of fund utilization patterns in bank accounts and determination of allowable interest based on initial investment share.
ITAT reversed CIT(A)'s addition under s.69 regarding unexplained property investment, accepting loan from assessee's mother as legitimate source after verification of her creditworthiness in reopened assessment. On interest disallowance under s.24, ITAT directed AO to verify if assessee's investment from borrowed funds was limited to their ownership share. Interest deduction permitted only on borrowed funds used for initial property investment up to assessee's share portion, following prudent investment principle. Subsequent investments, even if from borrowed funds, deemed ineligible for s.24 interest deduction. Matter remanded to AO for verification of fund utilization patterns in bank accounts and determination of allowable interest based on initial investment share.
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