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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Dividend distribution tax was treated as a charge on the distributed profits of the domestic company, not as tax on the non-resident shareholder's income for DTAA purposes, so the India-Netherlands treaty did not support the refund claim. The Tribunal also held that the refund application was not maintainable because no return of income had been filed in accordance with the statutory refund procedure. On both grounds, the assessee's appeals were dismissed.
Dividend distribution tax was treated as a charge on the distributed profits of the domestic company, not as tax on the non-resident shareholder's income for DTAA purposes, so the India-Netherlands treaty did not support the refund claim. The Tribunal also held that the refund application was not maintainable because no return of income had been filed in accordance with the statutory refund procedure. On both grounds, the assessee's appeals were dismissed.
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