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 ...
MEIS scrip income and duty drawback were treated as operating revenue for transfer pricing because they arose directly from the assessee's export and manufacturing activities; excluding them would distort operating profit, and the absence of similar incentives in comparables was not decisive. The Tribunal also directed examination of the working capital computation on record and grant of an appropriate adjustment while determining arm's length price. On CSR-linked donations, deduction under section 80G was allowed because CSR disallowance as business expenditure does not automatically bar section 80G relief, and the statutory exclusions were not shown to apply.
MEIS scrip income and duty drawback were treated as operating revenue for transfer pricing because they arose directly from the assessee's export and manufacturing activities; excluding them would distort operating profit, and the absence of similar incentives in comparables was not decisive. The Tribunal also directed examination of the working capital computation on record and grant of an appropriate adjustment while determining arm's length price. On CSR-linked donations, deduction under section 80G was allowed because CSR disallowance as business expenditure does not automatically bar section 80G relief, and the statutory exclusions were not shown to apply.
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