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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
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