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 - Corporate/Management services fee - TPO cannot reject the allowability of expenses simply on the ground that no benefit was derived - It is for the assessee to decide the way in which it has to carry on its business - Once it is proved that the services were availed, then TPO jurisdiction gets restricted to determining the ALP of the transaction.
TP adjustment - Corporate/Management services fee - TPO cannot reject the allowability of expenses simply on the ground that no benefit was derived - It is for the assessee to decide the way in which it has to carry on its business - Once it is proved that the services were availed, then TPO jurisdiction gets restricted to determining the ALP of the transaction.
Note: It is a system-generated summary and is for quick reference only.
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