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 ...
Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude certain companies. Transfer pricing adjustment for interest on receivables - TPO's calculation of interest on entire closing balance incorrect. TPO instructed to compute interest based on delay for each invoice beyond grace period after examining agreements or market practice. Employee's PF contribution disallowed for non-compliance with statutory deposit timelines. No long-term capital gain on amount credited to capital reserve pursuant to merger, covered u/s 47(vi). Double addition in computation corrected. Finance cost disallowance deleted as no transfer pricing adjustment proposed. Advance tax credit and TDS credit from merged entity directed to be allowed based on evidence.
Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude certain companies. Transfer pricing adjustment for interest on receivables - TPO's calculation of interest on entire closing balance incorrect. TPO instructed to compute interest based on delay for each invoice beyond grace period after examining agreements or market practice. Employee's PF contribution disallowed for non-compliance with statutory deposit timelines. No long-term capital gain on amount credited to capital reserve pursuant to merger, covered u/s 47(vi). Double addition in computation corrected. Finance cost disallowance deleted as no transfer pricing adjustment proposed. Advance tax credit and TDS credit from merged entity directed to be allowed based on evidence.
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