SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
ITAT held that surrender proceeds of a Unit Linked Insurance Policy constitute a "capital asset" within section 2(14) and directed the AO to assess accruals on surrender under the head "capital gains" with allowance for indexation, rejecting taxation as "income from other sources." The Tribunal observed that provisos to section 10(10D) effective 01.04.2021 are inapplicable to the assessment year in issue and that mere deduction of TDS does not determine the nature of the receipt. The AO is directed to re-assess the receipt as capital gains and to grant credit for TDS as reflected in Form 26AS when giving effect to this order.
ITAT held that surrender proceeds of a Unit Linked Insurance Policy constitute a "capital asset" within section 2(14) and directed the AO to assess accruals on surrender under the head "capital gains" with allowance for indexation, rejecting taxation as "income from other sources." The Tribunal observed that provisos to section 10(10D) effective 01.04.2021 are inapplicable to the assessment year in issue and that mere deduction of TDS does not determine the nature of the receipt. The AO is directed to re-assess the receipt as capital gains and to grant credit for TDS as reflected in Form 26AS when giving effect to this order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
