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 ...
Section 56(2)(viib) share-premium additions may not arise where the issue price of unquoted shares exceeds the Rule 11UA value by no more than 10%. The CBDT's curative safe-harbour amendment treats the issue price within that permissible variation as fair market value. Applying this safe harbour, an addition for excess share premium within the 10% range was treated as unsustainable and deleted.
Section 56(2)(viib) share-premium additions may not arise where the issue price of unquoted shares exceeds the Rule 11UA value by no more than 10%. The CBDT's curative safe-harbour amendment treats the issue price within that permissible variation as fair market value. Applying this safe harbour, an addition for excess share premium within the 10% range was treated as unsustainable and deleted.
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