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 ...
Research and Development expenses (R&D Expenses) - Allowability of expenses u/s 35(2) - The expenses are not covered u/s 35(2) - The assessee has not claimed the same u/s 35(2) but the expenses are allowable u/s 35(1) @ 100%. Since, the ratio of incurring of expenses per se is not in dispute, we hold that the assessee is eligible to claim expenses u/s 35(1). The approval of the DSIR is not required for claim u/s 35(1)(i). - AT
Research and Development expenses (R&D Expenses) - Allowability of expenses u/s 35(2) - The expenses are not covered u/s 35(2) - The assessee has not claimed the same u/s 35(2) but the expenses are allowable u/s 35(1) @ 100%. Since, the ratio of incurring of expenses per se is not in dispute, we hold that the assessee is eligible to claim expenses u/s 35(1). The approval of the DSIR is not required for claim u/s 35(1)(i). - AT
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