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 ...
One-time settlement paid to contractors was treated as revenue business expenditure incurred wholly and exclusively for business purposes; the Tribunal accepted that the contractors remained responsible for their workers, tax was deducted at source, and the payments were made to avoid disruption during restructuring, so the full deduction was allowed and the four-fifths disallowance deleted. The disallowance linked to exempt income was remitted because the Assessing Officer proceeded on the mistaken assumption that no suo motu disallowance existed, while the assessee had not fully supported its computation, requiring fresh examination after considering the computation and further material. The treaty-rate claim on dividend distribution tax was admitted as a pure legal ground and remitted for decision after the Supreme Court's final ruling on the controversy.
One-time settlement paid to contractors was treated as revenue business expenditure incurred wholly and exclusively for business purposes; the Tribunal accepted that the contractors remained responsible for their workers, tax was deducted at source, and the payments were made to avoid disruption during restructuring, so the full deduction was allowed and the four-fifths disallowance deleted. The disallowance linked to exempt income was remitted because the Assessing Officer proceeded on the mistaken assumption that no suo motu disallowance existed, while the assessee had not fully supported its computation, requiring fresh examination after considering the computation and further material. The treaty-rate claim on dividend distribution tax was admitted as a pure legal ground and remitted for decision after the Supreme Court's final ruling on the controversy.
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