Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Compulsory-acquisition compensation attributable to development rights transferred under a pre-existing development agreement is discussed as not accruing to the land-holding company where the developer held exclusive commercial rights, funded the acquisition, and bore development risks. The notes distinguish an overriding contractual obligation from an application of income after accrual. They further state that taxing the same transferred compensation again in the land-holder's hands, after its taxation in the developer's hands, would create impermissible double taxation without statutory authority. Consistent treatment is also identified as relevant where materially identical development arrangements have received different tax treatment.
Compulsory-acquisition compensation attributable to development rights transferred under a pre-existing development agreement is discussed as not accruing to the land-holding company where the developer held exclusive commercial rights, funded the acquisition, and bore development risks. The notes distinguish an overriding contractual obligation from an application of income after accrual. They further state that taxing the same transferred compensation again in the land-holder's hands, after its taxation in the developer's hands, would create impermissible double taxation without statutory authority. Consistent treatment is also identified as relevant where materially identical development arrangements have received different tax treatment.
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