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 ...
Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
Note: It is a system-generated summary and is for quick reference only.