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 ...
HC rejected the assessee's claim for expenditure under 'debtors' head, finding insufficient evidence to support alleged trade practice of cash discounts. The Tribunal's findings were upheld, determining that the payments included non-revenue items like loan repayments and investments. The court concluded that without substantive proof of legitimate business expenditure, the original assessment stands. Appeals under Section 260A were dismissed, with questions answered in favor of the Revenue and against the assessee, affirming the Tribunal's original determination of non-allowable expenditure.
HC rejected the assessee's claim for expenditure under 'debtors' head, finding insufficient evidence to support alleged trade practice of cash discounts. The Tribunal's findings were upheld, determining that the payments included non-revenue items like loan repayments and investments. The court concluded that without substantive proof of legitimate business expenditure, the original assessment stands. Appeals under Section 260A were dismissed, with questions answered in favor of the Revenue and against the assessee, affirming the Tribunal's original determination of non-allowable expenditure.
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