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...
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ITAT held that the final assessment order was void ab initio due to non-compliance with DRP directions under Section 144C(13). The tribunal found the Assessing Officer (AO) did not follow specific procedural requirements, rendering the assessment order invalid. Regarding intra-group services (IGS), the tribunal allowed the assessee's claim, determining that the payments were genuine, made without markup, and benchmarked appropriately. The tribunal emphasized that tax authorities cannot question expenses when transactions are legitimate and serve business purposes. The disallowance of intra-group service charges was consequently deleted, upholding the arm's length principle and rejecting the need for a strict tangible commercial benefit test.
ITAT held that the final assessment order was void ab initio due to non-compliance with DRP directions under Section 144C(13). The tribunal found the Assessing Officer (AO) did not follow specific procedural requirements, rendering the assessment order invalid. Regarding intra-group services (IGS), the tribunal allowed the assessee's claim, determining that the payments were genuine, made without markup, and benchmarked appropriately. The tribunal emphasized that tax authorities cannot question expenses when transactions are legitimate and serve business purposes. The disallowance of intra-group service charges was consequently deleted, upholding the arm's length principle and rejecting the need for a strict tangible commercial benefit test.
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