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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Transfer pricing comparability was applied on functional profile and reliable data: Datamatics Business Solutions was excluded because it performed high-end KPO functions unlike a routine captive BPO, while R Systems International could be included if quarterly public results enable a reliable margin computation. Micro Land was included on consistency grounds despite not appearing in the search matrix. Working capital differences under TNMM required fresh verification, and interest on delayed foreign-currency receivables was to be recomputed using LIBOR plus 200 basis points for the actual delay period. The section 43B disallowance was restored for factual verification, and interest under sections 234A and 234C was held unsustainable or required recomputation in the assessee's favour.
Transfer pricing comparability was applied on functional profile and reliable data: Datamatics Business Solutions was excluded because it performed high-end KPO functions unlike a routine captive BPO, while R Systems International could be included if quarterly public results enable a reliable margin computation. Micro Land was included on consistency grounds despite not appearing in the search matrix. Working capital differences under TNMM required fresh verification, and interest on delayed foreign-currency receivables was to be recomputed using LIBOR plus 200 basis points for the actual delay period. The section 43B disallowance was restored for factual verification, and interest under sections 234A and 234C was held unsustainable or required recomputation in the assessee's favour.
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