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 ...
Penalty under s. 270A(1) r/w s. 270A(9)(c) for alleged false expense claims was examined where the underlying addition comprised an ad hoc disallowance sustained at 20% on an estimated basis. Since the income adjustment was purely estimative and did not meet the statutory parameters of "under-reported income" warranting penal consequences, and the AO had not recorded the requisite satisfaction to justify levy under s. 270A, the penalty was held arbitrary and void ab initio. Penalty was quashed and the appeal was allowed. - ITAT
Penalty under s. 270A(1) r/w s. 270A(9)(c) for alleged false expense claims was examined where the underlying addition comprised an ad hoc disallowance sustained at 20% on an estimated basis. Since the income adjustment was purely estimative and did not meet the statutory parameters of "under-reported income" warranting penal consequences, and the AO had not recorded the requisite satisfaction to justify levy under s. 270A, the penalty was held arbitrary and void ab initio. Penalty was quashed and the appeal was allowed. - ITAT
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