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 ...
Short deduction of TDS - Non residents not having PAN - TDS @10% or 20% - invoking the provisions of Section 206AA - the PANs now made available for both the assessment years, the deductees are mostly from USA, China, Korea, Finland and Italy. DTAAs are available with all these five countries - the provisions of DTAA prevail over the provisions of I.T. Act, 1961 - AT
Short deduction of TDS - Non residents not having PAN - TDS @10% or 20% - invoking the provisions of Section 206AA - the PANs now made available for both the assessment years, the deductees are mostly from USA, China, Korea, Finland and Italy. DTAAs are available with all these five countries - the provisions of DTAA prevail over the provisions of I.T. Act, 1961 - AT
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