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 ...
ITAT partially allowed the appeal, holding that the transaction with Kamineni Health Care Pvt. Ltd. was an investment, not a loan, thereby deleting the disallowance of interest expenses. For the loan to United Steel Allied Ind Private Limited, the Tribunal upheld the CIT(A)'s view, directing the AO to levy interest for the actual loan period. The Tribunal found the assessee failed to substantiate claims of commercial exigency or business connection between the companies, thus treating the advances as loans under section 36(1)(iii) of the Income Tax Act. The appeal was consequently partly allowed with specific directions to the Assessing Officer.
ITAT partially allowed the appeal, holding that the transaction with Kamineni Health Care Pvt. Ltd. was an investment, not a loan, thereby deleting the disallowance of interest expenses. For the loan to United Steel Allied Ind Private Limited, the Tribunal upheld the CIT(A)'s view, directing the AO to levy interest for the actual loan period. The Tribunal found the assessee failed to substantiate claims of commercial exigency or business connection between the companies, thus treating the advances as loans under section 36(1)(iii) of the Income Tax Act. The appeal was consequently partly allowed with specific directions to the Assessing Officer.
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