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 on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee to its A.E. As noted above, the transaction is not reimbursement of expenses by the assessee to its A.E. and rather, is reimbursement of expenses by the A.E. to the assessee. - The adjustment made in respect of international transactions of reimbursement of the sea farers expenses is based on incorrect appreciation of facts. - Directed to be deleted - AT
TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee to its A.E. As noted above, the transaction is not reimbursement of expenses by the assessee to its A.E. and rather, is reimbursement of expenses by the A.E. to the assessee. - The adjustment made in respect of international transactions of reimbursement of the sea farers expenses is based on incorrect appreciation of facts. - Directed to be deleted - AT
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