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 ...
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Business and management consultancy charges closely linked to the assessee's operations were held to be benchmarked on an aggregated basis under TNMM, not by a separate ALP analysis, where receipt of services was supported by additional evidence; the matter was remitted for fresh examination by the TPO after considering that evidence. For outstanding receivables from the associated enterprise, the Tribunal applied average LIBOR as the appropriate benchmark rate for delayed payment interest, rejecting the ad hoc higher rate adopted by the lower authorities. The appeal was partly allowed, with consultancy charges sent back for recomputation and receivable interest directed to be recalculated using average LIBOR.
Business and management consultancy charges closely linked to the assessee's operations were held to be benchmarked on an aggregated basis under TNMM, not by a separate ALP analysis, where receipt of services was supported by additional evidence; the matter was remitted for fresh examination by the TPO after considering that evidence. For outstanding receivables from the associated enterprise, the Tribunal applied average LIBOR as the appropriate benchmark rate for delayed payment interest, rejecting the ad hoc higher rate adopted by the lower authorities. The appeal was partly allowed, with consultancy charges sent back for recomputation and receivable interest directed to be recalculated using average LIBOR.
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