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 on account of interest paid on delayed payment of TDS - as the tax deducted at source (TDS) is not in the nature of the income tax which is required to be paid on profits & gains chargeable to tax u/s. 28 of the Act and thus not disallowable u/s. 40(a)(ii) of the Act, the consequent the interest paid u/s. 201(1A) of the Act upon late payment of TDS also cannot be disallowed u/s. 40(a)(ii) of the Act. - AT
Disallowance on account of interest paid on delayed payment of TDS - as the tax deducted at source (TDS) is not in the nature of the income tax which is required to be paid on profits & gains chargeable to tax u/s. 28 of the Act and thus not disallowable u/s. 40(a)(ii) of the Act, the consequent the interest paid u/s. 201(1A) of the Act upon late payment of TDS also cannot be disallowed u/s. 40(a)(ii) of the Act. - AT
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