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...
Internal comparable pricing for captive power transfers was accepted where the same consuming units bought electricity from State distribution companies in the same market and period, resulting in deletion of transfer-pricing adjustments. Exempt-income disallowance was confined to dividend-yielding investments, and MAT adjustments required an independent determination of expenditure from the accounts. Expansion-related operating costs remained revenue expenditure unless directly attributable to acquiring or installing capital assets. Captive rail systems qualified as infrastructure facilities for section 80-IA, while common costs required expenditure-based allocation supported by a nexus. Incentives linked to capital investment and expansion were treated as capital receipts and excluded from book profit. The notes also address investment allowance, additional depreciation, bad debts, leave encashment, and specified MAT adjustments.
Internal comparable pricing for captive power transfers was accepted where the same consuming units bought electricity from State distribution companies in the same market and period, resulting in deletion of transfer-pricing adjustments. Exempt-income disallowance was confined to dividend-yielding investments, and MAT adjustments required an independent determination of expenditure from the accounts. Expansion-related operating costs remained revenue expenditure unless directly attributable to acquiring or installing capital assets. Captive rail systems qualified as infrastructure facilities for section 80-IA, while common costs required expenditure-based allocation supported by a nexus. Incentives linked to capital investment and expansion were treated as capital receipts and excluded from book profit. The notes also address investment allowance, additional depreciation, bad debts, leave encashment, and specified MAT adjustments.
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