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 ...
MAT computation u/s 115JB - addition of the amortization of Intangibles - The intangible assets are acquired and owned by the assessee company pursuant to the approved Scheme.- There is perpetual and irrevocable transfer of the intangible assets such as Trade Marks to the assessee company. - The contention of the Ld. AO that there was no transfer of ownership of the assets to the assessee company is incorrect - Addition deleted - AT
MAT computation u/s 115JB - addition of the amortization of Intangibles - The intangible assets are acquired and owned by the assessee company pursuant to the approved Scheme.- There is perpetual and irrevocable transfer of the intangible assets such as Trade Marks to the assessee company. - The contention of the Ld. AO that there was no transfer of ownership of the assets to the assessee company is incorrect - Addition deleted - AT
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