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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
ITAT adjudicated a tax dispute involving surface rights and intangible asset depreciation claims. The tribunal partially allowed the assessee's appeal, permitting amortization of surface rights based on evidence that the mining rights acquisition did not confer tangible benefits to the transferor entity. Regarding depreciation on equity shares issued free of cost, the tribunal rejected the claim, finding no demonstrable business advantage or documentary proof of technical support. The tribunal sustained lower authorities' orders, dismissing the assessee's claim for depreciation on the purported intangible asset. The decision emphasized the necessity of substantive evidence to support tax deduction claims related to business rights and asset acquisitions.
ITAT adjudicated a tax dispute involving surface rights and intangible asset depreciation claims. The tribunal partially allowed the assessee's appeal, permitting amortization of surface rights based on evidence that the mining rights acquisition did not confer tangible benefits to the transferor entity. Regarding depreciation on equity shares issued free of cost, the tribunal rejected the claim, finding no demonstrable business advantage or documentary proof of technical support. The tribunal sustained lower authorities' orders, dismissing the assessee's claim for depreciation on the purported intangible asset. The decision emphasized the necessity of substantive evidence to support tax deduction claims related to business rights and asset acquisitions.
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