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 ...
TDS u/s 195 - non deduction of TDS - demurrage charges paid by the respondent-assessee to the foreign companies - The ITAT upheld the decision of the CIT(A) to delete the addition of demurrage charges, citing the precedent set by the Full Bench of the Bombay High Court.
TDS u/s 195 - non deduction of TDS - demurrage charges paid by the respondent-assessee to the foreign companies - The ITAT upheld the decision of the CIT(A) to delete the addition of demurrage charges, citing the precedent set by the Full Bench of the Bombay High Court.
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