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 ...
In the case before ITAT Chennai, the issue of disallowance u/s 14A r.w.r. 8D was considered. The CIT(A) found that no exempt income was earned by the assessee, leading to full relief being granted. The order of the CIT(A) and AO regarding disallowance was set aside, directing the AO to delete the addition from the total income. Regarding TDS u/s 195 for listing charges paid to Bank of New York, it was noted that DTAA provisions were not considered. The AO was directed to re-examine the issue in light of DTAA provisions. The claim of prior period expenditure was dismissed as it cannot be allowed in the assessment of a specific year. The writing off of carbon income was remanded to the AO for re-examination based on past treatment by the Department. The issue was decided in favor of the assessee for statistical purposes only.
In the case before ITAT Chennai, the issue of disallowance u/s 14A r.w.r. 8D was considered. The CIT(A) found that no exempt income was earned by the assessee, leading to full relief being granted. The order of the CIT(A) and AO regarding disallowance was set aside, directing the AO to delete the addition from the total income. Regarding TDS u/s 195 for listing charges paid to Bank of New York, it was noted that DTAA provisions were not considered. The AO was directed to re-examine the issue in light of DTAA provisions. The claim of prior period expenditure was dismissed as it cannot be allowed in the assessment of a specific year. The writing off of carbon income was remanded to the AO for re-examination based on past treatment by the Department. The issue was decided in favor of the assessee for statistical purposes only.
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