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) - shortfall in deduction of tax at source due to difference in opinion - no disallowance could be made by invoking provisions of section 40(a)(ia) of the Act, if there is any short fall in the action of tax at source due to difference of understanding our opinion as to the taxability of any item or nature of payment falling under various TDS provisions - AT
Disallowance u/s 40(a)(ia) - shortfall in deduction of tax at source due to difference in opinion - no disallowance could be made by invoking provisions of section 40(a)(ia) of the Act, if there is any short fall in the action of tax at source due to difference of understanding our opinion as to the taxability of any item or nature of payment falling under various TDS provisions - AT
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