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 two key issues: (1) Disallowance of "Other Discounts" and (2) Addition under Section 45(4). In the first matter, the Tribunal reversed lower authorities' disallowance, finding the discount was a legitimate prompt payment discount substantiated by subsequent invoices and party-specific details. Regarding Section 45(4), the Tribunal held that introducing a new partner with fresh capital does not constitute asset transfer, thus Section 45(4) was inapplicable. Relying on judicial precedents, the Tribunal directed the Assessing Officer to delete the addition, ultimately deciding both grounds in favor of the assessee.
ITAT adjudicated two key issues: (1) Disallowance of "Other Discounts" and (2) Addition under Section 45(4). In the first matter, the Tribunal reversed lower authorities' disallowance, finding the discount was a legitimate prompt payment discount substantiated by subsequent invoices and party-specific details. Regarding Section 45(4), the Tribunal held that introducing a new partner with fresh capital does not constitute asset transfer, thus Section 45(4) was inapplicable. Relying on judicial precedents, the Tribunal directed the Assessing Officer to delete the addition, ultimately deciding both grounds in favor of the assessee.
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