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...
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Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
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