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 ...
Disallowance u/s 40(a)(ia) - payment of pigmy commission had direct nexus with the business income of the assessee on which deduction u/s 80P(2)(a)(i) was claimed - If the disallowance u/s.40(a)(i) results in increase in income which would otherwise go to enhance the income on which the Assessee is eligible for deduction, then the CBDT Circular would be applicable and deduction will be allowable
Disallowance u/s 40(a)(ia) - payment of pigmy commission had direct nexus with the business income of the assessee on which deduction u/s 80P(2)(a)(i) was claimed - If the disallowance u/s.40(a)(i) results in increase in income which would otherwise go to enhance the income on which the Assessee is eligible for deduction, then the CBDT Circular would be applicable and deduction will be allowable
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