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...
Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
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