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 ...
Income accrued in India - FTS - No PE in India - DTAA between India and UAE - As per DTAA, there is no specific clause in respect of FTS and same has to be considered as business profit in the absence of such clause and permanent establishment in India.
Income accrued in India - FTS - No PE in India - DTAA between India and UAE - As per DTAA, there is no specific clause in respect of FTS and same has to be considered as business profit in the absence of such clause and permanent establishment in India.
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