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 ...
TP adjustment - comparable selection - Rule 10B(4)- the data to be used in analysing the comparability of an uncontrolled transaction shall be the data relating to the financial year - proviso to this rule further provides that data relating to a period not being more than two years prior to [the current year] may also be considered if such data have an influence on the determination of TP in relation to the transactions being compared
TP adjustment - comparable selection - Rule 10B(4)- the data to be used in analysing the comparability of an uncontrolled transaction shall be the data relating to the financial year - proviso to this rule further provides that data relating to a period not being more than two years prior to [the current year] may also be considered if such data have an influence on the determination of TP in relation to the transactions being compared
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