Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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Receipts claimed as advances for sale of land were taxed as income from other sources because the assessee could not establish ownership, possession, or any surviving contingent right in the land, and the factual basis for treating the sums as capital receipts failed. The Tribunal held that, absent any proved property right or transfer, the amounts were taxable in the hands of the assessee. It also sustained reopening under section 147 for A.Y. 2009-10, holding that an error in the recorded quantum of receipt did not undermine the underlying reason to believe, since the MOU, the deal value, and the receipt itself remained undisputed.
Receipts claimed as advances for sale of land were taxed as income from other sources because the assessee could not establish ownership, possession, or any surviving contingent right in the land, and the factual basis for treating the sums as capital receipts failed. The Tribunal held that, absent any proved property right or transfer, the amounts were taxable in the hands of the assessee. It also sustained reopening under section 147 for A.Y. 2009-10, holding that an error in the recorded quantum of receipt did not undermine the underlying reason to believe, since the MOU, the deal value, and the receipt itself remained undisputed.
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