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) does not apply where shares are issued as non-cash consideration for acquiring a business undertaking, because no money is received; the share-premium addition was deleted. Bad-debt deductions were allowed where receivables had been taxed earlier and were written off, including student-fee receivables supported by detailed records. Section 14A disallowance was deleted in the absence of exempt income. Reversal of advance or unearned fees did not attract sections 41(1) or 28(iv) where no earlier deduction or benefit arose, and acknowledged creditor liabilities were not treated as ceased. Loan processing charges were allowable as interest-related business expenditure. TDS-related relief depended on the payee offering income to tax; other disallowances were sustained, restricted, or remanded according to the applicable rules and evidence of liability crystallisation.
Section 56(2)(viib) does not apply where shares are issued as non-cash consideration for acquiring a business undertaking, because no money is received; the share-premium addition was deleted. Bad-debt deductions were allowed where receivables had been taxed earlier and were written off, including student-fee receivables supported by detailed records. Section 14A disallowance was deleted in the absence of exempt income. Reversal of advance or unearned fees did not attract sections 41(1) or 28(iv) where no earlier deduction or benefit arose, and acknowledged creditor liabilities were not treated as ceased. Loan processing charges were allowable as interest-related business expenditure. TDS-related relief depended on the payee offering income to tax; other disallowances were sustained, restricted, or remanded according to the applicable rules and evidence of liability crystallisation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
