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...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
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