Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Appellate proceedings cannot be used to introduce a new head of income or enhance an assessment without following the prescribed procedure. Where the original dispute concerned only denial of deduction under section 54F on the basis of alleged multiple residential units and a claimed sham transfer, and the appellate authority accepted that the transfer was lawful, that controversy stood concluded. The further step of taxing the share-sale consideration under section 56 amounted to an unauthorised enhancement and a change in the basis of assessment. The appellate order was therefore unsustainable, and the deduction under section 54F was directed to be allowed.
Appellate proceedings cannot be used to introduce a new head of income or enhance an assessment without following the prescribed procedure. Where the original dispute concerned only denial of deduction under section 54F on the basis of alleged multiple residential units and a claimed sham transfer, and the appellate authority accepted that the transfer was lawful, that controversy stood concluded. The further step of taxing the share-sale consideration under section 56 amounted to an unauthorised enhancement and a change in the basis of assessment. The appellate order was therefore unsustainable, and the deduction under section 54F was directed to be allowed.
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