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 ...
HC upheld revision under s.263 regarding treatment of provision for doubtful debts in computing book profits under s.115-JB. AO's acceptance of assessee's claim was mechanical, without examining why provision for doubtful assets was claimed as deduction despite not being debited to provision account. Amount was merely shown as reduction from trade receivables for disclosure, not as written-off debts. Assessee maintained recovery hopes. PCIT's jurisdiction exercise directing re-examination was justified. Tribunal correctly analyzed legal position, finding no illegality in CIT's order. HC found no jurisdictional infirmity, ruling against assessee's appeal.
HC upheld revision under s.263 regarding treatment of provision for doubtful debts in computing book profits under s.115-JB. AO's acceptance of assessee's claim was mechanical, without examining why provision for doubtful assets was claimed as deduction despite not being debited to provision account. Amount was merely shown as reduction from trade receivables for disclosure, not as written-off debts. Assessee maintained recovery hopes. PCIT's jurisdiction exercise directing re-examination was justified. Tribunal correctly analyzed legal position, finding no illegality in CIT's order. HC found no jurisdictional infirmity, ruling against assessee's appeal.
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