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 ...
Revision u/s 263 - Disallowance u/s 40(a)(ia) on non deduction of TDS - The Tribunal found that the Principal Commissioner had incorrectly invoked section 263 as the payments and Tax Deducted at Source (TDS) were related to the subsequent financial year and there was no revenue implication or prejudice to the Revenue.
Revision u/s 263 - Disallowance u/s 40(a)(ia) on non deduction of TDS - The Tribunal found that the Principal Commissioner had incorrectly invoked section 263 as the payments and Tax Deducted at Source (TDS) were related to the subsequent financial year and there was no revenue implication or prejudice to the Revenue.
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