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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 ...
A receipt under a collaboration agreement was treated as a business transaction, not an unexplained cash credit, because it moved through account-to-account banking channels and the payer's bank account showed no cash deposit before transfer. The assessee produced corporate records, PAN, returns, accounts and bank statements establishing identity, creditworthiness and genuineness; once that material was filed, the burden shifted to the department, which was not discharged. The Tribunal found the accommodation entry allegation unsupported by enquiry and based on suspicion, and deleted the section 68 addition. The reassessment ground was left open and not decided.
A receipt under a collaboration agreement was treated as a business transaction, not an unexplained cash credit, because it moved through account-to-account banking channels and the payer's bank account showed no cash deposit before transfer. The assessee produced corporate records, PAN, returns, accounts and bank statements establishing identity, creditworthiness and genuineness; once that material was filed, the burden shifted to the department, which was not discharged. The Tribunal found the accommodation entry allegation unsupported by enquiry and based on suspicion, and deleted the section 68 addition. The reassessment ground was left open and not decided.
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