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...
Exempt dividend income earned by assessee. Interest-free owned funds exceeded investments in tax-free securities, disallowance u/r 8D(2)(ii) not warranted. For Rule 8D(2)(iii) disallowance, only investments yielding exempt income to be considered, recomputation directed. No adjustment for section 14A disallowance to book profits u/s 115JB, as not proposed in draft order or directed by DRP. Discount to pre-paid distributors not subject to TDS u/s 194H, no disallowance u/s 40(a)(ia). Depreciation on 3G spectrum allowed u/s 32(1)(ii). Brand royalty payment to AE remanded to TPO/AO for fresh benchmarking. Reimbursement of expenses to AE remanded for substantiation. Additional TDS credit to be granted as per law after verification. Legal terminology from Income Tax Act and Rules used.
Exempt dividend income earned by assessee. Interest-free owned funds exceeded investments in tax-free securities, disallowance u/r 8D(2)(ii) not warranted. For Rule 8D(2)(iii) disallowance, only investments yielding exempt income to be considered, recomputation directed. No adjustment for section 14A disallowance to book profits u/s 115JB, as not proposed in draft order or directed by DRP. Discount to pre-paid distributors not subject to TDS u/s 194H, no disallowance u/s 40(a)(ia). Depreciation on 3G spectrum allowed u/s 32(1)(ii). Brand royalty payment to AE remanded to TPO/AO for fresh benchmarking. Reimbursement of expenses to AE remanded for substantiation. Additional TDS credit to be granted as per law after verification. Legal terminology from Income Tax Act and Rules used.
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