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)(i) - failure to deduct TDS for the AY 2012-13 - AO is directed to allow the deduction of expenses on being satisfied that the tax has been deducted and paid during the previous year relating to AY 204-15 towards expenses in controversy. It shall be open to the assessee to support its claim before the AO in this regard with proof of payment of taxes in the light of aforesaid observations.
Disallowance u/s 40 (a)(i) - failure to deduct TDS for the AY 2012-13 - AO is directed to allow the deduction of expenses on being satisfied that the tax has been deducted and paid during the previous year relating to AY 204-15 towards expenses in controversy. It shall be open to the assessee to support its claim before the AO in this regard with proof of payment of taxes in the light of aforesaid observations.
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