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 ...
TNMM comparability must remain functionally robust: several software service comparables were excluded for lack of functional similarity, aggregate related-party transaction filtering was required for all selected comparables, and certain companies were restored for fresh FAR analysis or year-end data review. Working capital adjustment was restored because comparable margins must be adjusted for material profit-affecting differences; risk adjustment was refused for lack of demonstrated quantification, and delayed receivables were to be recomputed after giving effect to the final working capital adjustment. The mark-up on reimbursements was deleted for lack of factual and legal basis, interest income on the loan was remanded for fresh real-income examination, prepaid tax credit on amalgamation was to be verified and granted where corresponding income was offered, and penalty initiation was held premature.
TNMM comparability must remain functionally robust: several software service comparables were excluded for lack of functional similarity, aggregate related-party transaction filtering was required for all selected comparables, and certain companies were restored for fresh FAR analysis or year-end data review. Working capital adjustment was restored because comparable margins must be adjusted for material profit-affecting differences; risk adjustment was refused for lack of demonstrated quantification, and delayed receivables were to be recomputed after giving effect to the final working capital adjustment. The mark-up on reimbursements was deleted for lack of factual and legal basis, interest income on the loan was remanded for fresh real-income examination, prepaid tax credit on amalgamation was to be verified and granted where corresponding income was offered, and penalty initiation was held premature.
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