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...
The ITAT deleted the addition for unexplained investment/purchases because the Revenue failed to produce material directly linking the assessee to the alleged unaccounted transactions with Tirth Gold. The Tribunal noted that the assessee had furnished ledger accounts, bank statement, GST registration certificate and a declaration from Tirth Gold stating that no sales were made to the assessee for the relevant assessment year, but these documents were overlooked. Reliance only on third-party statements and digital data, without corroboration identifying the assessee as involved in undisclosed purchases or investment, was insufficient to sustain the addition. The assessee's appeal was allowed.
The ITAT deleted the addition for unexplained investment/purchases because the Revenue failed to produce material directly linking the assessee to the alleged unaccounted transactions with Tirth Gold. The Tribunal noted that the assessee had furnished ledger accounts, bank statement, GST registration certificate and a declaration from Tirth Gold stating that no sales were made to the assessee for the relevant assessment year, but these documents were overlooked. Reliance only on third-party statements and digital data, without corroboration identifying the assessee as involved in undisclosed purchases or investment, was insufficient to sustain the addition. The assessee's appeal was allowed.
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