Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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 ...
Transactions in respect of which the impugned payments were made was purely on account of services and there is no transfer of right to use the goods - No TDS u/s 195 as as the same is not royalty - AT
Transactions in respect of which the impugned payments were made was purely on account of services and there is no transfer of right to use the goods - No TDS u/s 195 as as the same is not royalty - AT
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