Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
For property devolving on a beneficiary upon dissolution of a private family trust, the previous owner's holding period must be included where the previous owner's cost is adopted under section 49(1). Explanation 1(b) to section 2(42A) requires that deemed holding period to determine whether the asset is long-term; the properties therefore qualify as long-term capital assets. The same holding period applies to indexed cost of acquisition, which must be computed from the year in which the previous owner first held the property. Gains on the sale of such devolved immovable properties are accordingly taxable as long-term capital gains, and the related addition was deleted.
For property devolving on a beneficiary upon dissolution of a private family trust, the previous owner's holding period must be included where the previous owner's cost is adopted under section 49(1). Explanation 1(b) to section 2(42A) requires that deemed holding period to determine whether the asset is long-term; the properties therefore qualify as long-term capital assets. The same holding period applies to indexed cost of acquisition, which must be computed from the year in which the previous owner first held the property. Gains on the sale of such devolved immovable properties are accordingly taxable as long-term capital gains, and the related addition was deleted.
Note: It is a system-generated summary and is for quick reference only.