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 allowed the assessee's appeal for statistical purposes and remanded the matter to the Assessing Officer/Transfer Pricing Officer for fresh adjudication. Regarding the Transfer Pricing adjustment, the ITAT admitted additional evidence filed by the assessee and directed the TPO to determine the Most Appropriate Method for computing Arm's Length Price after considering the new evidence. Concerning the disallowance of business promotion expenses, the ITAT remitted the matter back to the Assessing Officer for fresh adjudication after the assessee agreed to file evidence.
The ITAT allowed the assessee's appeal for statistical purposes and remanded the matter to the Assessing Officer/Transfer Pricing Officer for fresh adjudication. Regarding the Transfer Pricing adjustment, the ITAT admitted additional evidence filed by the assessee and directed the TPO to determine the Most Appropriate Method for computing Arm's Length Price after considering the new evidence. Concerning the disallowance of business promotion expenses, the ITAT remitted the matter back to the Assessing Officer for fresh adjudication after the assessee agreed to file evidence.
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