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 ...
Addition for no TDS on Deemed dividend u/s 2(22)(e) - whether the amounts given the directors are for the business purpose? - the ledger account of the said directors does not reflect any transactions or details where from it can be perceived that the transactions are in the nature of normal business transactions, much less the said transactions were not substantiated with any documentary evidence substantiating that these pertains to or have any nexus with the business of the assessee company - However, no additions can be made u/s 40(a)(ia) on deemed dividend for no TDS - AT
Addition for no TDS on Deemed dividend u/s 2(22)(e) - whether the amounts given the directors are for the business purpose? - the ledger account of the said directors does not reflect any transactions or details where from it can be perceived that the transactions are in the nature of normal business transactions, much less the said transactions were not substantiated with any documentary evidence substantiating that these pertains to or have any nexus with the business of the assessee company - However, no additions can be made u/s 40(a)(ia) on deemed dividend for no TDS - AT
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