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 ...
TDS u/s 194C or 194I - car rent expenses incurred by assessee - variation in threshold limit - the assessee has deducted TDS u/s. 194I in respect of one of the lessor, from whom vehicle was taken on lease and that, the payment exceeded the threshold limit of ₹ 1,80,000/-. There is no malafide intention of assessee to evade tax. In respect of the remaining payments, the threshold limit did not exceed and therefore TDS need not have been deducted. We therefore direct the Ld.AO to delete the disallowance made in respect of the same. - AT
TDS u/s 194C or 194I - car rent expenses incurred by assessee - variation in threshold limit - the assessee has deducted TDS u/s. 194I in respect of one of the lessor, from whom vehicle was taken on lease and that, the payment exceeded the threshold limit of ₹ 1,80,000/-. There is no malafide intention of assessee to evade tax. In respect of the remaining payments, the threshold limit did not exceed and therefore TDS need not have been deducted. We therefore direct the Ld.AO to delete the disallowance made in respect of the same. - AT
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