Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Receipts from ancillary services connected with software licensing are considered in relation to their characterisation as fees for technical services and deemed accrual of income in India under section 9(1)(vi). The note records that the Tribunal's approach for a later assessment year relied on the Supreme Court's Engineering Analysis decision, whose review was subsequently dismissed. It further notes that no substantial question of law arose from the challenged order.
Receipts from ancillary services connected with software licensing are considered in relation to their characterisation as fees for technical services and deemed accrual of income in India under section 9(1)(vi). The note records that the Tribunal's approach for a later assessment year relied on the Supreme Court's Engineering Analysis decision, whose review was subsequently dismissed. It further notes that no substantial question of law arose from the challenged order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
