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 ...
Disallowance u/s 14A read with Rule 8D - Assessing Officer did not record objective satisfaction for not accepting suo moto disallowance made by assessee. ITAT directed Assessing Officer to accept suo moto disallowance made u/r 8D(2)(iii) read with Section 14A. Only investments not yielding exempt income should be considered for disallowance u/s 14A read with Rule 8D. Deduction u/s 80G for donations - Deduction allowable for sums paid as donation. Donations to specific Kosh and Fund not allowable u/s 80G(2)(a)(iiihk) and (iiihl). Amounts spent on CSR activities u/s 135 of Companies Act 2013 not allowable as deduction u/s 80G. Disallowance for deduction u/s 80G vis-a-vis CSR restricted to contributions to these Funds under CSR. No error in allowing deduction claimed u/s 80G, except for contributions to these two funds.
Disallowance u/s 14A read with Rule 8D - Assessing Officer did not record objective satisfaction for not accepting suo moto disallowance made by assessee. ITAT directed Assessing Officer to accept suo moto disallowance made u/r 8D(2)(iii) read with Section 14A. Only investments not yielding exempt income should be considered for disallowance u/s 14A read with Rule 8D. Deduction u/s 80G for donations - Deduction allowable for sums paid as donation. Donations to specific Kosh and Fund not allowable u/s 80G(2)(a)(iiihk) and (iiihl). Amounts spent on CSR activities u/s 135 of Companies Act 2013 not allowable as deduction u/s 80G. Disallowance for deduction u/s 80G vis-a-vis CSR restricted to contributions to these Funds under CSR. No error in allowing deduction claimed u/s 80G, except for contributions to these two funds.
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