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 ...
Allowability of Interest Expenditure - The Tribunal noted a delay of 418 days in filing the quantum appeal by the assessee, which was condoned as the assessee pursued an alternative legal remedy before the Commissioner of Income Tax (Appeals) [CIT(A)]. - The main issue was the disallowance of interest on the grounds that borrowed funds were utilized for non-business purposes. The Tribunal found that the CIT(A) did not appropriately consider the remand report from the Assessing Officer (AO), which detailed the utilization of borrowed funds. Therefore, the Tribunal restored the quantum appeal to the file of the CIT(A) for re-adjudication in light of the AO's remand report. - AT
Allowability of Interest Expenditure - The Tribunal noted a delay of 418 days in filing the quantum appeal by the assessee, which was condoned as the assessee pursued an alternative legal remedy before the Commissioner of Income Tax (Appeals) [CIT(A)]. - The main issue was the disallowance of interest on the grounds that borrowed funds were utilized for non-business purposes. The Tribunal found that the CIT(A) did not appropriately consider the remand report from the Assessing Officer (AO), which detailed the utilization of borrowed funds. Therefore, the Tribunal restored the quantum appeal to the file of the CIT(A) for re-adjudication in light of the AO's remand report. - AT
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