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 ...
A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
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