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 ...
TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not applicable, while remanding the matter back to the TPO for fresh determination - Transfer Pricing Officer is directed to redo the entire process of determination of ALP of international transactions with AE, without being influenced by any observation made by the Tribunal and render an independent finding with regard to the issues involved herein - HC
TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not applicable, while remanding the matter back to the TPO for fresh determination - Transfer Pricing Officer is directed to redo the entire process of determination of ALP of international transactions with AE, without being influenced by any observation made by the Tribunal and render an independent finding with regard to the issues involved herein - HC
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