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...
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Additions for unexplained money failed where the Revenue relied on presumption without independent corroboration. For the alleged cash payment to or on behalf of Ms. Jwala Gutta, the Tribunal found that the seized material did not establish that the assessee himself made any cash payment, and there was no confirmation from Ms. Gutta or other supporting evidence; the addition was deleted. For the alleged cash component of marriage expenses, the Assessing Officer made no enquiry from the recipient and did not properly examine the possibility of funding from Shagun receipts, so the addition was also deleted. The Tribunal treated both additions as unsupported by evidence and allowed the appeal, with the same view applied to the other assessment years.
Additions for unexplained money failed where the Revenue relied on presumption without independent corroboration. For the alleged cash payment to or on behalf of Ms. Jwala Gutta, the Tribunal found that the seized material did not establish that the assessee himself made any cash payment, and there was no confirmation from Ms. Gutta or other supporting evidence; the addition was deleted. For the alleged cash component of marriage expenses, the Assessing Officer made no enquiry from the recipient and did not properly examine the possibility of funding from Shagun receipts, so the addition was also deleted. The Tribunal treated both additions as unsupported by evidence and allowed the appeal, with the same view applied to the other assessment years.
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