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 ...
TDS liability u/s 195 - consideration paid by the assessee for purchasing of embedded software was to be treated as consideration for supply of goods and therefore, the same was taxable as business income and not as royalty - not subject to withholding tax u/s 195 - AT
TDS liability u/s 195 - consideration paid by the assessee for purchasing of embedded software was to be treated as consideration for supply of goods and therefore, the same was taxable as business income and not as royalty - not subject to withholding tax u/s 195 - AT
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