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 ...
Transfer pricing adjustment - Correspondent Banking Activities - The main business transactions have been accepted to be at arm’s length and hence, the ld. TPO cannot separately treat the incidental benefit as a separate transaction unless it is shown that they are separate from the main business activities. - No transfer pricing adjustment on account of correspondent banking activity is warranted in the instant case
Transfer pricing adjustment - Correspondent Banking Activities - The main business transactions have been accepted to be at arm’s length and hence, the ld. TPO cannot separately treat the incidental benefit as a separate transaction unless it is shown that they are separate from the main business activities. - No transfer pricing adjustment on account of correspondent banking activity is warranted in the instant case
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