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 held that cash deposits supported by recorded cash sales could not be treated as unexplained cash credit where the assessee produced purchase and sales registers, no specific discrepancy was found in sales, purchases or cash book, and the books were not rejected; absence of a stock register alone was insufficient, so the section 68 addition on that account was deleted. For the claimed capital introduction based on an alleged gift, the appellate relief was unsustainable because the new material was not properly tested through due process, including verification of the donor's identity, genuineness and creditworthiness; that issue was set aside and remanded to the AO for de novo adjudication.
ITAT held that cash deposits supported by recorded cash sales could not be treated as unexplained cash credit where the assessee produced purchase and sales registers, no specific discrepancy was found in sales, purchases or cash book, and the books were not rejected; absence of a stock register alone was insufficient, so the section 68 addition on that account was deleted. For the claimed capital introduction based on an alleged gift, the appellate relief was unsustainable because the new material was not properly tested through due process, including verification of the donor's identity, genuineness and creditworthiness; that issue was set aside and remanded to the AO for de novo adjudication.
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