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 u/s 195 - Disallowance u/s. 40(a)(i) - FTS - it cannot be said that the rendering of services by the non residents to the assessee made available to the assessee , such services , for its future use or utilization on a reasonably permanent basis - since the amount is not taxable, TDS is required to be deducted - AT
TDS u/s 195 - Disallowance u/s. 40(a)(i) - FTS - it cannot be said that the rendering of services by the non residents to the assessee made available to the assessee , such services , for its future use or utilization on a reasonably permanent basis - since the amount is not taxable, TDS is required to be deducted - AT
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