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 ...
Disallowance of deduction u/s 80IA(4)(i) - The tribunal noted the distinction between a developer (who assumes significant risks and responsibilities for the project) and a contractor (who does not assume such risks and is only responsible for executing work as per the contract) - The tribunal directed that, based on the nature of contracts and risks assumed, the assessee's claim for deductions under Section 80IA(4) should be allowed, emphasizing the role of the assessee as a developer rather than a mere contractor.
Disallowance of deduction u/s 80IA(4)(i) - The tribunal noted the distinction between a developer (who assumes significant risks and responsibilities for the project) and a contractor (who does not assume such risks and is only responsible for executing work as per the contract) - The tribunal directed that, based on the nature of contracts and risks assumed, the assessee's claim for deductions under Section 80IA(4) should be allowed, emphasizing the role of the assessee as a developer rather than a mere contractor.
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