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 held that the revisionary proceedings u/s 263 were valid and the assessee cannot challenge the order since it had attained finality. In the substantive matter concerning unexplained cash credit u/s 68 for share capital and share premium from 18 private limited applicants, the tribunal found that the assessee successfully established the identity, genuineness, and creditworthiness of share applicants through their tax assessments, financial statements, and ROC scrutiny. Consequently, the tribunal deleted the addition u/s 68, set aside the CIT(A)'s order, and allowed the assessee's grounds 1-5, concluding no addition was warranted based on the comprehensive documentation and verification of investment sources.
ITAT held that the revisionary proceedings u/s 263 were valid and the assessee cannot challenge the order since it had attained finality. In the substantive matter concerning unexplained cash credit u/s 68 for share capital and share premium from 18 private limited applicants, the tribunal found that the assessee successfully established the identity, genuineness, and creditworthiness of share applicants through their tax assessments, financial statements, and ROC scrutiny. Consequently, the tribunal deleted the addition u/s 68, set aside the CIT(A)'s order, and allowed the assessee's grounds 1-5, concluding no addition was warranted based on the comprehensive documentation and verification of investment sources.
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