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 partially allowed the appeal, reducing the estimated income addition from 10% to 1.52% of declared turnover. Despite concerns about unaudited accounts and non-filing of returns, the tribunal recognized the assessee's self-declared figures and permitted a set-off of Rs. 1,49,165/-. The decision mandates the assessee to reconcile financial discrepancies while moderating the income addition imposed by the Assessing Officer, thereby striking a balance between procedural compliance and equitable tax assessment.
ITAT partially allowed the appeal, reducing the estimated income addition from 10% to 1.52% of declared turnover. Despite concerns about unaudited accounts and non-filing of returns, the tribunal recognized the assessee's self-declared figures and permitted a set-off of Rs. 1,49,165/-. The decision mandates the assessee to reconcile financial discrepancies while moderating the income addition imposed by the Assessing Officer, thereby striking a balance between procedural compliance and equitable tax assessment.
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