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 ...
Penalty under section 270A was deleted because the assessee had made a deduction claim under section 80GGC, and the Assessing Officer had examined that claim; mere disallowance of the deduction did not, on these facts, establish under-reporting or misreporting. The Tribunal also held the penalty order unsustainable because it did not specify the applicable limb of section 270A or set out the particulars required to satisfy sub-section (9). As the statutory basis and necessary ingredients were not properly identified, the penalty could not be sustained.
Penalty under section 270A was deleted because the assessee had made a deduction claim under section 80GGC, and the Assessing Officer had examined that claim; mere disallowance of the deduction did not, on these facts, establish under-reporting or misreporting. The Tribunal also held the penalty order unsustainable because it did not specify the applicable limb of section 270A or set out the particulars required to satisfy sub-section (9). As the statutory basis and necessary ingredients were not properly identified, the penalty could not be sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
