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...
Surplus interest-free funds support a presumption that investments were funded from those sources, where such funds exceed the investments. On that basis, interest expenditure could not be disallowed or capitalised as capital work in progress when the building had already been put to use in earlier years. The text also states that a disallowance computed under section 14A read with rule 8D cannot, merely for that reason, be added to book profit under section 115JB. It records that the appellate deletions were upheld, as the issues were covered by binding decisions and concurrent factual findings, with no substantial question of law arising.
Surplus interest-free funds support a presumption that investments were funded from those sources, where such funds exceed the investments. On that basis, interest expenditure could not be disallowed or capitalised as capital work in progress when the building had already been put to use in earlier years. The text also states that a disallowance computed under section 14A read with rule 8D cannot, merely for that reason, be added to book profit under section 115JB. It records that the appellate deletions were upheld, as the issues were covered by binding decisions and concurrent factual findings, with no substantial question of law arising.
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