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...
Eligible-industrial-unit deductions are discussed in relation to interest on staff advances and deposits, overdue customer-bill interest, and a Sikkim manufacturing unit. The notes distinguish interest not eligible for deduction from overdue-bill interest and address continuity where prior-year positions govern. They also cover exempt-income expenditure: sufficient interest-free own funds may preclude interest disallowance, while administrative expenditure is computed under the prescribed method. For LLP-interest transfers, partnership rights are capital assets, but related-party status and approved valuation require examination. In book-profit computation, the notes address exempt-income adjustments, intangible-asset amortisation, and treatment of a debenture redemption provision as an ascertained liability. They also explain appellate power to admit a lawful omitted claim evident from the record.
Eligible-industrial-unit deductions are discussed in relation to interest on staff advances and deposits, overdue customer-bill interest, and a Sikkim manufacturing unit. The notes distinguish interest not eligible for deduction from overdue-bill interest and address continuity where prior-year positions govern. They also cover exempt-income expenditure: sufficient interest-free own funds may preclude interest disallowance, while administrative expenditure is computed under the prescribed method. For LLP-interest transfers, partnership rights are capital assets, but related-party status and approved valuation require examination. In book-profit computation, the notes address exempt-income adjustments, intangible-asset amortisation, and treatment of a debenture redemption provision as an ascertained liability. They also explain appellate power to admit a lawful omitted claim evident from the record.
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