Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
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 4881 
