Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Permissive possession granted to a developer under a joint development agreement, solely for development and construction while ownership remains with the co-owners, does not constitute possession in part performance under section 53A of the Transfer of Property Act. Accordingly, section 2(47)(v) of the Income-tax Act is not attracted, and the agreement does not effect a transfer of the capital asset in the relevant previous year. The text notes that where the developer holds possession only as the owners' representative, no capital gains arise merely upon execution of the agreement.
Permissive possession granted to a developer under a joint development agreement, solely for development and construction while ownership remains with the co-owners, does not constitute possession in part performance under section 53A of the Transfer of Property Act. Accordingly, section 2(47)(v) of the Income-tax Act is not attracted, and the agreement does not effect a transfer of the capital asset in the relevant previous year. The text notes that where the developer holds possession only as the owners' representative, no capital gains arise merely upon execution of the agreement.
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