Advance-ruling mechanism governs pending GST classification, exemption and taxability disputes, limiting writ review once the specialised forum functi...
Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
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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