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 of interest - assessee had taken unsecured loans from the family members of the partners in the earlier years and paying interest @ 15% on the same - Fresh borrowing during the year from HDFC bank has been utilized for advancing to the partners and the family members and there is thus a direct nexus - it would have been appropriate to compare the related party transaction with an independent third party transaction carrying the same qualitative unsecured loan parameters.
Disallowance of interest - assessee had taken unsecured loans from the family members of the partners in the earlier years and paying interest @ 15% on the same - Fresh borrowing during the year from HDFC bank has been utilized for advancing to the partners and the family members and there is thus a direct nexus - it would have been appropriate to compare the related party transaction with an independent third party transaction carrying the same qualitative unsecured loan parameters.
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