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 adjudicated multiple tax issues for the assessee, rendering key decisions: On bad debt deduction, ITAT held that claiming ascertained bad debt in the current assessment year is permissible, considering the tax rate remained consistent across fiscal years. The tribunal allowed the assessee's claim, finding no procedural bar in claiming the deduction. Regarding data field costs, ITAT determined these expenditures constitute direct business expenses correlated with market research fees. The tribunal accepted the assessee's submission, noting the expenditures were duly audited and represented legitimate operational costs. In transfer pricing matters, ITAT directed the AO/TPO to include a profitable comparable company in the economic analysis, rejecting persistent loss criteria. The tribunal also declined to treat provisions written back as operating income, emphasizing insufficient demonstration of direct business linkage.
ITAT adjudicated multiple tax issues for the assessee, rendering key decisions: On bad debt deduction, ITAT held that claiming ascertained bad debt in the current assessment year is permissible, considering the tax rate remained consistent across fiscal years. The tribunal allowed the assessee's claim, finding no procedural bar in claiming the deduction. Regarding data field costs, ITAT determined these expenditures constitute direct business expenses correlated with market research fees. The tribunal accepted the assessee's submission, noting the expenditures were duly audited and represented legitimate operational costs. In transfer pricing matters, ITAT directed the AO/TPO to include a profitable comparable company in the economic analysis, rejecting persistent loss criteria. The tribunal also declined to treat provisions written back as operating income, emphasizing insufficient demonstration of direct business linkage.
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