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 ...
Deduction u/s 80IA(4) - Disallowance of project facility expenses - Revenue expenses or Capital expenditure - Appellant was engaged in infrastructure development and toll road operation - Ld. CIT(A) upheld the appellant's claim, stating that these expenses did not create capital assets and were eligible for deduction under Section 80IA(4). The tribunal, following the principle of consistency, upheld the Ld. CIT(A)'s decision, citing precedents where similar deductions were allowed, and dismissed the Revenue's appeal. Condonation of Delay: Despite the initial delay, the tri
Deduction u/s 80IA(4) - Disallowance of project facility expenses - Revenue expenses or Capital expenditure - Appellant was engaged in infrastructure development and toll road operation - Ld. CIT(A) upheld the appellant's claim, stating that these expenses did not create capital assets and were eligible for deduction under Section 80IA(4). The tribunal, following the principle of consistency, upheld the Ld. CIT(A)'s decision, citing precedents where similar deductions were allowed, and dismissed the Revenue's appeal. Condonation of Delay: Despite the initial delay, the tri
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