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 ...
Classification of automotive electronic control units depends on their distinct functions rather than the generic label "ECU". Body Control Modules and Integrated Body Units fall under the tariff entry for electronic automatic regulators, following an earlier Tribunal order in the same party's matter; absent any superior forum order altering that position, judicial discipline requires consistent treatment. Tyre Pressure Monitoring Systems were also accepted under that entry because the proposed motor-vehicle-parts classification lacked evidence establishing the functional characteristics required for reclassification. Revenue bears the burden of proving classification under a tariff heading different from that claimed, and the related demand and interest were set aside.
Classification of automotive electronic control units depends on their distinct functions rather than the generic label "ECU". Body Control Modules and Integrated Body Units fall under the tariff entry for electronic automatic regulators, following an earlier Tribunal order in the same party's matter; absent any superior forum order altering that position, judicial discipline requires consistent treatment. Tyre Pressure Monitoring Systems were also accepted under that entry because the proposed motor-vehicle-parts classification lacked evidence establishing the functional characteristics required for reclassification. Revenue bears the burden of proving classification under a tariff heading different from that claimed, and the related demand and interest were set aside.
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