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 ...
The ITAT Hyderabad upheld the estimation of income and profit, dismissing Revenue's appeal. The profit was modified to 11.5%. Deduction u/s 80-IA(4) was disallowed based on precedent. Disallowance of interest u/s 14A r.w.r 8D and section 36(1)(iii) was rejected due to business exigency. Interest earned on FDs was not taxed as it was already reduced from finance charges. Cash payments u/s 40A(3) were justified due to lack of banking facilities at remote sites. Business promotion expenses were allowed as connected to business promotion, given income estimation. The findings of CIT(A) were upheld, and Revenue's appeal was dismissed.
The ITAT Hyderabad upheld the estimation of income and profit, dismissing Revenue's appeal. The profit was modified to 11.5%. Deduction u/s 80-IA(4) was disallowed based on precedent. Disallowance of interest u/s 14A r.w.r 8D and section 36(1)(iii) was rejected due to business exigency. Interest earned on FDs was not taxed as it was already reduced from finance charges. Cash payments u/s 40A(3) were justified due to lack of banking facilities at remote sites. Business promotion expenses were allowed as connected to business promotion, given income estimation. The findings of CIT(A) were upheld, and Revenue's appeal was dismissed.
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