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...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Tax-transparent UK partnerships determine treaty entitlement for their Indian-source income by reference to each partner's country of residence. The text distinguishes legal and professional services from fees for technical services, stating that legal-service receipts cannot be characterised as fees for technical services under section 9(1)(vii). It records deletion of the related addition, while requiring examination of the treaty liability of partners resident outside the UK under their respective treaties. Claimed advance-tax and tax-deducted-at-source credits require verification before being granted in accordance with law.
Tax-transparent UK partnerships determine treaty entitlement for their Indian-source income by reference to each partner's country of residence. The text distinguishes legal and professional services from fees for technical services, stating that legal-service receipts cannot be characterised as fees for technical services under section 9(1)(vii). It records deletion of the related addition, while requiring examination of the treaty liability of partners resident outside the UK under their respective treaties. Claimed advance-tax and tax-deducted-at-source credits require verification before being granted in accordance with law.
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