Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
Fees for technical services (FTS) - nature of payment - the assessee was not exploiting the D&D for business purposes, that IPR of the D&D were retained by the non resident supplier - disputed amount cannot be considered as FTS - AT
Fees for technical services (FTS) - nature of payment - the assessee was not exploiting the D&D for business purposes, that IPR of the D&D were retained by the non resident supplier - disputed amount cannot be considered as FTS - AT
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