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 ...
Where additional income declared during search was credited as loans, it was held that, since the taxpayer's only activity was land trading and the amount was already offered and accepted as business income, it could not be taxed as unexplained cash credit under s.68 read with s.115BBE; the addition was deleted. On alleged on-money enhancing capital gains, unsigned and undated seized notings and lack of corroboration, coupled with some plots not being sold as alleged, were held insufficient; the addition was deleted. Direction to verify telescoping/set-off of disclosed income against other additions was sustained. Deletion of s.69C addition was upheld for want of error in appreciation of explained expenditure. Addition under s.69 read with s.115BBE based on cancelled loose-paper notings, without corroboration, was set aside. - ITAT
Where additional income declared during search was credited as loans, it was held that, since the taxpayer's only activity was land trading and the amount was already offered and accepted as business income, it could not be taxed as unexplained cash credit under s.68 read with s.115BBE; the addition was deleted. On alleged on-money enhancing capital gains, unsigned and undated seized notings and lack of corroboration, coupled with some plots not being sold as alleged, were held insufficient; the addition was deleted. Direction to verify telescoping/set-off of disclosed income against other additions was sustained. Deletion of s.69C addition was upheld for want of error in appreciation of explained expenditure. Addition under s.69 read with s.115BBE based on cancelled loose-paper notings, without corroboration, was set aside. - ITAT
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