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 ...
Exemption u/s 11 - seeking benefit on the ground of mutuality in case of denial of benefit of section 11 by invoking section 13 - the assessee has clearly gave the details to the Assessing Officer that it has dealt only with the 140 non-members and details of their subscriptions, it shows that the assessee kept the record of dealing with the non-members. Therefore, we are inclined to remit this issue back to the file of Assessing Officer to evaluate the allowability of benefit under mutuality concept to the assessee.- AT
Exemption u/s 11 - seeking benefit on the ground of mutuality in case of denial of benefit of section 11 by invoking section 13 - the assessee has clearly gave the details to the Assessing Officer that it has dealt only with the 140 non-members and details of their subscriptions, it shows that the assessee kept the record of dealing with the non-members. Therefore, we are inclined to remit this issue back to the file of Assessing Officer to evaluate the allowability of benefit under mutuality concept to the assessee.- AT
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