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 ...
AAAR affirmed that the appellant is not entitled to avoid reversal of input tax credit (ITC) on common inputs and input services relating to mutual fund subscription and redemption, holding that the deeming provision in section 17(3) incorporates "transactions in securities" into the value of exempt supplies for ITC reversal. The authority rejected the contention that "securities" exclusion from goods/services removes them from exempt/non-taxable supply treatment and construed the Rule reference to "sale value" consistently with "transactions in securities," encompassing redemptions. The AAAR also found no substantiation that subscription/redemption activities were in the course or furtherance of the appellant's business. The appeal is dismissed.
AAAR affirmed that the appellant is not entitled to avoid reversal of input tax credit (ITC) on common inputs and input services relating to mutual fund subscription and redemption, holding that the deeming provision in section 17(3) incorporates "transactions in securities" into the value of exempt supplies for ITC reversal. The authority rejected the contention that "securities" exclusion from goods/services removes them from exempt/non-taxable supply treatment and construed the Rule reference to "sale value" consistently with "transactions in securities," encompassing redemptions. The AAAR also found no substantiation that subscription/redemption activities were in the course or furtherance of the appellant's business. The appeal is dismissed.
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