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 ...
Computation of deduction u/s 10AA - The Tribunal examined the details provided by the assessee regarding expenses incurred in foreign currency. It noted that the Assessing Officer had excluded these expenses without thorough examination. The Tribunal referred to a previous decision by the Madras High Court in a similar case and held that the order of the Commissioner of Income Tax (Appeals) was not justified in confirming the exclusion. It allowed the appeal on this ground.
Computation of deduction u/s 10AA - The Tribunal examined the details provided by the assessee regarding expenses incurred in foreign currency. It noted that the Assessing Officer had excluded these expenses without thorough examination. The Tribunal referred to a previous decision by the Madras High Court in a similar case and held that the order of the Commissioner of Income Tax (Appeals) was not justified in confirming the exclusion. It allowed the appeal on this ground.
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