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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Exemption u/s 80-IC - Claim denied as no work was carried at the Baddi Unit - There is no concrete material on record which would suggest that the assessee’s claim was not genuine and no work was carried at the Baddi Unit. The fact that the assessee had one internet connection / AC or inadequate computer facilities or the fact the bank accounts were not maintained at Baddi location is only a matter of perception and nothing conclusive could be borne out of those observations. Assessee had well substantiated its claim of deduction u/s 80-I - AT
Exemption u/s 80-IC - Claim denied as no work was carried at the Baddi Unit - There is no concrete material on record which would suggest that the assessee’s claim was not genuine and no work was carried at the Baddi Unit. The fact that the assessee had one internet connection / AC or inadequate computer facilities or the fact the bank accounts were not maintained at Baddi location is only a matter of perception and nothing conclusive could be borne out of those observations. Assessee had well substantiated its claim of deduction u/s 80-I - AT
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