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...
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TDS u/s 194C - determination of job work charges / miller cost - milling of paddy - As per AO milling costs paid by the appellant are discounted costs and need to be increased by the cost of by-products for the purpose of TDS - since we have held that the property in the by-product was not passed on by the assessee / Procurement Agencies as milling charges, hence, it is held that TDS provisions of section 194C are not attracted in this case. - AT
TDS u/s 194C - determination of job work charges / miller cost - milling of paddy - As per AO milling costs paid by the appellant are discounted costs and need to be increased by the cost of by-products for the purpose of TDS - since we have held that the property in the by-product was not passed on by the assessee / Procurement Agencies as milling charges, hence, it is held that TDS provisions of section 194C are not attracted in this case. - AT
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