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 ...
Trade receivables under TNMM were treated as integral to the international transactions, so a separate notional interest adjustment was deleted where working capital adjustment had already captured the receivables impact and no distinct financing arrangement was shown. Goodwill arising on amalgamation was accepted as a depreciable acquired intangible, and depreciation was allowed. Product registration and regulatory approval were held to be revenue in nature because they facilitated existing business operations rather than creating a capital asset. For section 80-IC, the Tribunal upheld full deduction on manufacturing profits without hypothetical brand-royalty allocation, included scrap income as derived from manufacturing, and confirmed 100% deduction after substantial expansion in line with Aarham Softronics.
Trade receivables under TNMM were treated as integral to the international transactions, so a separate notional interest adjustment was deleted where working capital adjustment had already captured the receivables impact and no distinct financing arrangement was shown. Goodwill arising on amalgamation was accepted as a depreciable acquired intangible, and depreciation was allowed. Product registration and regulatory approval were held to be revenue in nature because they facilitated existing business operations rather than creating a capital asset. For section 80-IC, the Tribunal upheld full deduction on manufacturing profits without hypothetical brand-royalty allocation, included scrap income as derived from manufacturing, and confirmed 100% deduction after substantial expansion in line with Aarham Softronics.
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