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 dismissed challenges to any question of law regarding disallowance of royalty paid by the assessee to its AE, holding that the TPO's role is confined to determining arm's-length price and not to interrogate commercial efficacy; factual findings that manufacturers were subcontractors and no royalty was paid abroad remain uncontroverted. Transfer-pricing adjustments to AMP expenses (both substantive and protective) are deleted, the Tribunal's application of both the intensity approach and the BLT being held not in accordance with law. The assessee's method of valuing opening and closing stock at cost or net realisable value is upheld. The claim for a lower rate of DDT is rejected and decided against the assessee.
The ITAT dismissed challenges to any question of law regarding disallowance of royalty paid by the assessee to its AE, holding that the TPO's role is confined to determining arm's-length price and not to interrogate commercial efficacy; factual findings that manufacturers were subcontractors and no royalty was paid abroad remain uncontroverted. Transfer-pricing adjustments to AMP expenses (both substantive and protective) are deleted, the Tribunal's application of both the intensity approach and the BLT being held not in accordance with law. The assessee's method of valuing opening and closing stock at cost or net realisable value is upheld. The claim for a lower rate of DDT is rejected and decided against the assessee.
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