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 ...
The ITAT addressed a transfer pricing dispute involving management and technical assistance services between an assessee and its associated enterprise (AE). The Tribunal found that the payments were subject to TDS and declared taxable by the AE in India, negating profit shifting allegations. The Tribunal directed the Transfer Pricing Officer (TPO) to comprehensively examine the technical assistance agreement, verify additional evidence, and determine the arm's length price (ALP) considering the technical knowhow and formula provided. The appeal was allowed for statistical purposes, with the matter remanded to the TPO for detailed reassessment of the international transaction's pricing methodology.
The ITAT addressed a transfer pricing dispute involving management and technical assistance services between an assessee and its associated enterprise (AE). The Tribunal found that the payments were subject to TDS and declared taxable by the AE in India, negating profit shifting allegations. The Tribunal directed the Transfer Pricing Officer (TPO) to comprehensively examine the technical assistance agreement, verify additional evidence, and determine the arm's length price (ALP) considering the technical knowhow and formula provided. The appeal was allowed for statistical purposes, with the matter remanded to the TPO for detailed reassessment of the international transaction's pricing methodology.
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