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 ...
Eligible CSR donations qualify for deduction where they are made to institutions covered by section 80G and are not contributions to Swachh Bharat Kosh or Clean Ganga Fund. Explanation 2 to section 37(1) prevents CSR expenditure from being claimed as business expenditure, but does not bar relief under other provisions. A statutory CSR obligation does not remove a payment's character as a donation when an eligible mode is voluntarily selected; the deduction was therefore granted. Dividend distribution tax on dividends paid to a UK holding company is limited to the beneficial rate under Article 11 of the India-UK tax treaty. Tax retained above that rate was required to be refunded.
Eligible CSR donations qualify for deduction where they are made to institutions covered by section 80G and are not contributions to Swachh Bharat Kosh or Clean Ganga Fund. Explanation 2 to section 37(1) prevents CSR expenditure from being claimed as business expenditure, but does not bar relief under other provisions. A statutory CSR obligation does not remove a payment's character as a donation when an eligible mode is voluntarily selected; the deduction was therefore granted. Dividend distribution tax on dividends paid to a UK holding company is limited to the beneficial rate under Article 11 of the India-UK tax treaty. Tax retained above that rate was required to be refunded.
Note: It is a system-generated summary and is for quick reference only.
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