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...
Corporate guarantee furnished to an associated enterprise was treated as a separate international transaction, not a shareholder activity, and the 1% guarantee fee was upheld as arm's length on an internal CUP based on fees charged to other associated enterprises. The bad debt disallowance was deleted because, after the statutory amendment, the assessee need not prove actual irrecoverability once the debt is written off as irrecoverable in the accounts. Lease rentals in a finance lease were also held deductible as revenue expenditure, since book capitalization under AS-19 does not govern tax treatment and depreciation belongs to the legal owner, the lessor.
Corporate guarantee furnished to an associated enterprise was treated as a separate international transaction, not a shareholder activity, and the 1% guarantee fee was upheld as arm's length on an internal CUP based on fees charged to other associated enterprises. The bad debt disallowance was deleted because, after the statutory amendment, the assessee need not prove actual irrecoverability once the debt is written off as irrecoverable in the accounts. Lease rentals in a finance lease were also held deductible as revenue expenditure, since book capitalization under AS-19 does not govern tax treatment and depreciation belongs to the legal owner, the lessor.
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