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 ...
MAT computation - adjustment of rent/lease equalization reserve u/s 115JB of the Act - The Assessee contended that the reserve was not covered under Explanation 1(b) or 1(c) to section 115JB of the Act. The Tribunal agreed, referencing judgments that clarified such reserves are not to be added back while computing book profits under section 115JA. Hence, the addition made by the Assessing Officer deleted.
MAT computation - adjustment of rent/lease equalization reserve u/s 115JB of the Act - The Assessee contended that the reserve was not covered under Explanation 1(b) or 1(c) to section 115JB of the Act. The Tribunal agreed, referencing judgments that clarified such reserves are not to be added back while computing book profits under section 115JA. Hence, the addition made by the Assessing Officer deleted.
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