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 addressed taxation of income declared on excess stock found during survey, applying the principle that surrendered income arising from the same business activities must be taxed as business income rather than treated as undisclosed investment; outcome: CIT(A)'s direction to treat the surrender as regular business income is upheld. On disallowance of expenses for lack of documentary support, AO's additions were restored because vouchers were treated as self-made and expenses paid in cash. Claims for twice-booked meal expenses were disallowed and CIT(A)'s partial relief set aside. Vehicle expenditure disallowance based on absence of logbook/support was also restored to the AO's higher disallowance.
ITAT addressed taxation of income declared on excess stock found during survey, applying the principle that surrendered income arising from the same business activities must be taxed as business income rather than treated as undisclosed investment; outcome: CIT(A)'s direction to treat the surrender as regular business income is upheld. On disallowance of expenses for lack of documentary support, AO's additions were restored because vouchers were treated as self-made and expenses paid in cash. Claims for twice-booked meal expenses were disallowed and CIT(A)'s partial relief set aside. Vehicle expenditure disallowance based on absence of logbook/support was also restored to the AO's higher disallowance.
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