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...
Related-party interest expenditure may be disallowed only to the extent it is excessive compared with fair market value; where the interest on an unsecured related-party loan is not excessive, the related expenditure is not disallowable. The provision does not permit a corresponding adjustment by taxing notional interest income from a related party, and separate loan and current accounts cannot be consolidated merely because they involve the same party. Employees' PF and ESI contributions paid after the prescribed due date remain disallowable. Claims for related-party software services, maintenance and brokerage require adequate evidence of the services or facilitation actually provided; unsupported claims fail the genuineness test.
Related-party interest expenditure may be disallowed only to the extent it is excessive compared with fair market value; where the interest on an unsecured related-party loan is not excessive, the related expenditure is not disallowable. The provision does not permit a corresponding adjustment by taxing notional interest income from a related party, and separate loan and current accounts cannot be consolidated merely because they involve the same party. Employees' PF and ESI contributions paid after the prescribed due date remain disallowable. Claims for related-party software services, maintenance and brokerage require adequate evidence of the services or facilitation actually provided; unsupported claims fail the genuineness test.
Note: It is a system-generated summary and is for quick reference only.
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