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...
The Tribunal addressed double disallowance of a subsidiary investment write-off by noting that the amount had already been added back in the return, so the Assessing Officer had duplicated the disallowance; the duplicate addition was to be deleted and the allowed deduction then given effect. It also accepted that fresh claims may be entertained on appeal and excluded broken period interest on debentures because the income had only accrued notionally and was already absorbed in the later capital gains on sale, avoiding double taxation. A dividend treaty-rate claim for non-resident shareholders was remanded for lack of foundational treaty-eligibility and tax-treatment material, and the challenge to initiation of penalty proceedings was dismissed as premature.
The Tribunal addressed double disallowance of a subsidiary investment write-off by noting that the amount had already been added back in the return, so the Assessing Officer had duplicated the disallowance; the duplicate addition was to be deleted and the allowed deduction then given effect. It also accepted that fresh claims may be entertained on appeal and excluded broken period interest on debentures because the income had only accrued notionally and was already absorbed in the later capital gains on sale, avoiding double taxation. A dividend treaty-rate claim for non-resident shareholders was remanded for lack of foundational treaty-eligibility and tax-treatment material, and the challenge to initiation of penalty proceedings was dismissed as premature.
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