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 u/s 40(a)(ia) - External Development Charges(EDC) paid to HUDA without deduction of tax at source - TDS on EDC u/s 194C/194I - The tribunal concluded that since the EDC payment to HUDA was deposited in the consolidated Fund of the State, no tax deduction was required, thereby affirming the deletion of the disallowance. - The tribunal dismissed the revenue's appeal, upholding the CIT(A)'s order regarding the disallowance of EDC expenditure.
Disallowance u/s 40(a)(ia) - External Development Charges(EDC) paid to HUDA without deduction of tax at source - TDS on EDC u/s 194C/194I - The tribunal concluded that since the EDC payment to HUDA was deposited in the consolidated Fund of the State, no tax deduction was required, thereby affirming the deletion of the disallowance. - The tribunal dismissed the revenue's appeal, upholding the CIT(A)'s order regarding the disallowance of EDC expenditure.
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