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 ruled on multiple taxation issues for a cooperative society, primarily addressing status classification and tax liability. The tribunal predominantly decided in favor of the assessee, remitting several grounds back to the Assessing Officer for verification. Key holdings include: rejecting the change of status from cooperative society to banking company, negating dividend distribution tax applicability, partially allowing disallowance of expenditures, and directing recalculation of certain tax additions. The tribunal reduced vehicle expense disallowance from 15% to 10%, set aside various additions pending further verification, and confirmed minimal additions where insufficient evidence was provided. Overall, the decision provided significant relief to the assessee by challenging arbitrary tax assessments and requiring substantive proof for disallowances.
ITAT ruled on multiple taxation issues for a cooperative society, primarily addressing status classification and tax liability. The tribunal predominantly decided in favor of the assessee, remitting several grounds back to the Assessing Officer for verification. Key holdings include: rejecting the change of status from cooperative society to banking company, negating dividend distribution tax applicability, partially allowing disallowance of expenditures, and directing recalculation of certain tax additions. The tribunal reduced vehicle expense disallowance from 15% to 10%, set aside various additions pending further verification, and confirmed minimal additions where insufficient evidence was provided. Overall, the decision provided significant relief to the assessee by challenging arbitrary tax assessments and requiring substantive proof for disallowances.
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