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 addressed multiple taxation issues for the assessee across assessment years. Key outcomes include: directing deletion of depreciation disallowance related to demerger, allowing software expenses as revenue expenditure, permitting travel expenses for foreign executives, restricting section 14A disallowance to 2% of dividend income, and restoring certain issues to the Assessing Officer for fresh examination. The Tribunal consistently followed precedent decisions from earlier years, modifying the CIT(A)'s order on several grounds and providing specific directions for computational adjustments in various tax-related matters.
The ITAT addressed multiple taxation issues for the assessee across assessment years. Key outcomes include: directing deletion of depreciation disallowance related to demerger, allowing software expenses as revenue expenditure, permitting travel expenses for foreign executives, restricting section 14A disallowance to 2% of dividend income, and restoring certain issues to the Assessing Officer for fresh examination. The Tribunal consistently followed precedent decisions from earlier years, modifying the CIT(A)'s order on several grounds and providing specific directions for computational adjustments in various tax-related matters.
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