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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Legal issues related to income tax assessments, including the designation of tax authorities, allowability of deductions, disallowances under specific sections, transfer pricing adjustments, and procedural aspects. Key points are: Designation of Additional Commissioner as TPO is valid. Pro-rata deduction for leasehold lands allowed, subject to quantum verification. Write-back of provision for doubtful debts remitted for re-examination. Interest on tax refund to be granted as per assessee's claim. Disallowance u/r 8D restricted to exempt income-yielding investments. Such disallowance not applicable for computing book profits u/s 115JB. Expenditure on FCCN issue allowed as debenture issuance cost. Deduction u/s 80G disallowed due to loss. Transfer pricing adjustments on export of vehicles and interest on loans to AEs remitted for re-adjudication. Adjustments on purchase of property from AE and rent from leased property to AE deleted. TDS credit short allowed. Interest u/s 234D upheld. Additional ground regarding time-barred assessment dismissed based on precedent. Concise coverage of critical issues using relevant terminology.
Legal issues related to income tax assessments, including the designation of tax authorities, allowability of deductions, disallowances under specific sections, transfer pricing adjustments, and procedural aspects. Key points are: Designation of Additional Commissioner as TPO is valid. Pro-rata deduction for leasehold lands allowed, subject to quantum verification. Write-back of provision for doubtful debts remitted for re-examination. Interest on tax refund to be granted as per assessee's claim. Disallowance u/r 8D restricted to exempt income-yielding investments. Such disallowance not applicable for computing book profits u/s 115JB. Expenditure on FCCN issue allowed as debenture issuance cost. Deduction u/s 80G disallowed due to loss. Transfer pricing adjustments on export of vehicles and interest on loans to AEs remitted for re-adjudication. Adjustments on purchase of property from AE and rent from leased property to AE deleted. TDS credit short allowed. Interest u/s 234D upheld. Additional ground regarding time-barred assessment dismissed based on precedent. Concise coverage of critical issues using relevant terminology.
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