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...
Section 194B is described as applying the TDS threshold to each individual payment of online-game winnings, rather than to aggregated wallet balances, under the version applicable to the relevant year. The discussion notes that later statutory amendments introducing aggregation, followed by a single-transaction standard, do not expand the earlier provision. It further explains that section 40(a)(ia) disallows otherwise deductible expenditure and cannot apply where player payouts were neither debited to the Profit and Loss Account nor claimed as deductions. Payments for advertising-platform access to a non-resident are discussed as not constituting royalty or fees for technical services, following an earlier coordinate-Bench approach.
Section 194B is described as applying the TDS threshold to each individual payment of online-game winnings, rather than to aggregated wallet balances, under the version applicable to the relevant year. The discussion notes that later statutory amendments introducing aggregation, followed by a single-transaction standard, do not expand the earlier provision. It further explains that section 40(a)(ia) disallows otherwise deductible expenditure and cannot apply where player payouts were neither debited to the Profit and Loss Account nor claimed as deductions. Payments for advertising-platform access to a non-resident are discussed as not constituting royalty or fees for technical services, following an earlier coordinate-Bench approach.
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