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...
Year-end provisions for identified resident professional fees are treated as amounts on which tax must be deducted at source when the liability is created, so disallowance can arise if TDS is not deducted at that stage. Where deducted tax is deposited on or before the return-filing due date, the related expenditure is allowable for that year; if deposit is later, allowance shifts to the year of actual payment. Payments to offshore lawyers require examination of chargeability in India and any treaty protection before withholding is determined. A provision later reversed because the amount was not payable is treated as an unascertained liability and is not allowable.
Year-end provisions for identified resident professional fees are treated as amounts on which tax must be deducted at source when the liability is created, so disallowance can arise if TDS is not deducted at that stage. Where deducted tax is deposited on or before the return-filing due date, the related expenditure is allowable for that year; if deposit is later, allowance shifts to the year of actual payment. Payments to offshore lawyers require examination of chargeability in India and any treaty protection before withholding is determined. A provision later reversed because the amount was not payable is treated as an unascertained liability and is not allowable.
Note: It is a system-generated summary and is for quick reference only.
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