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...
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
Controlled transactions cannot be used as CUP comparables for brand royalty, so that adjustment was deleted. ECB interest benchmarking accepted RBI approval as a relevant contemporaneous benchmark and deleted the adjustment. AMP expenditure was not treated as an international transaction without tangible evidence of an arrangement. Depreciation on 3G spectrum rights, DoT subscriber verification payments, prepaid distributor discount and IBM hardware lease rentals were allowed, while liabilities written back were sustained and asset restoration cost was allowed as revenue expenditure. Annual licence fee remained capital in nature with only recomputation of amortisation under the telecom licence regime, and WPC royalty charges were also allowed.
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