Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Characterisation of losses on transfer of real-estate allotment rights depends on their actual treatment and supporting evidence, not book entries alone. Where the rights were recorded as short-term loans and advances rather than closing stock, and the claimed business loss was not substantiated, they were treated as capital assets. The resulting loss remained eligible for indexation and carry-forward as long-term capital loss. Where interest is claimed as part of acquisition cost, conflicting positions require fresh computation after the taxpayer is given an opportunity to provide supporting evidence.
Characterisation of losses on transfer of real-estate allotment rights depends on their actual treatment and supporting evidence, not book entries alone. Where the rights were recorded as short-term loans and advances rather than closing stock, and the claimed business loss was not substantiated, they were treated as capital assets. The resulting loss remained eligible for indexation and carry-forward as long-term capital loss. Where interest is claimed as part of acquisition cost, conflicting positions require fresh computation after the taxpayer is given an opportunity to provide supporting evidence.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
