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 ...
An APA covering the relevant year required the Arm's Length Price for international transactions to be reconsidered with reference to the APA terms, so the Assessing Officer was directed to rework the transfer pricing adjustment in accordance with law. The MAT book profit adjustment was also sent back because the assessment order did not discuss the addition and the assessee had not been given an opportunity of hearing; the officer was directed to reconsider the book profit computation after hearing the assessee and in light of the section 143(1) intimation. The interest and fee computation was remanded for verification of the extended due date, and interest under section 234B was held mandatory, subject to consequential recomputation after giving effect to the revised figures.
An APA covering the relevant year required the Arm's Length Price for international transactions to be reconsidered with reference to the APA terms, so the Assessing Officer was directed to rework the transfer pricing adjustment in accordance with law. The MAT book profit adjustment was also sent back because the assessment order did not discuss the addition and the assessee had not been given an opportunity of hearing; the officer was directed to reconsider the book profit computation after hearing the assessee and in light of the section 143(1) intimation. The interest and fee computation was remanded for verification of the extended due date, and interest under section 234B was held mandatory, subject to consequential recomputation after giving effect to the revised figures.
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