Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Permissive possession granted to a developer solely to construct flats does not amount to legal possession in part performance of a contract. Such limited entry, unlike possession involving control over property contemplated for part performance, does not constitute a transfer for capital-gains purposes. Accordingly, no long-term capital-gains charge arose from the development agreement, and the related addition was deleted.
Permissive possession granted to a developer solely to construct flats does not amount to legal possession in part performance of a contract. Such limited entry, unlike possession involving control over property contemplated for part performance, does not constitute a transfer for capital-gains purposes. Accordingly, no long-term capital-gains charge arose from the development agreement, and the related addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
