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...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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Pharmaceutical sales-promotion expenditure is disallowable only where it directly provides prohibited benefits, such as travel or hotel facilities, to medical practitioners; patient education, professional events and other non-prohibited promotional costs remain deductible. A retracted search statement without independent corroboration cannot support an over-invoicing addition. Manufacturing scrap and empty-container sales qualify for profit-linked deductions, while the industrial excise-refund incentive described is a capital receipt excluded from taxable income and book profit. Transfer-pricing analysis requires reliable functional, temporal and economic comparability; unsupported adjustments for domestic transactions, export pricing, guarantees and genuine intra-group services were rejected. The note also addresses exempt-income expenditure, foreign tax credit attribution, and independent examination of approved in-house research expenditure.
Pharmaceutical sales-promotion expenditure is disallowable only where it directly provides prohibited benefits, such as travel or hotel facilities, to medical practitioners; patient education, professional events and other non-prohibited promotional costs remain deductible. A retracted search statement without independent corroboration cannot support an over-invoicing addition. Manufacturing scrap and empty-container sales qualify for profit-linked deductions, while the industrial excise-refund incentive described is a capital receipt excluded from taxable income and book profit. Transfer-pricing analysis requires reliable functional, temporal and economic comparability; unsupported adjustments for domestic transactions, export pricing, guarantees and genuine intra-group services were rejected. The note also addresses exempt-income expenditure, foreign tax credit attribution, and independent examination of approved in-house research expenditure.
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