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 ...
Classification of services - Franchise services or not - slump sale of business of marketing - None of the ingredients of franchisee service or the Board Circular are present in the BPA between the Appellant and M/s Aventis - the Appellants do not qualify as Franchisor as the trademarks have been permanently assigned to M/s Aventis and they have become absolute owner with no control of the Appellant - no service tax
Classification of services - Franchise services or not - slump sale of business of marketing - None of the ingredients of franchisee service or the Board Circular are present in the BPA between the Appellant and M/s Aventis - the Appellants do not qualify as Franchisor as the trademarks have been permanently assigned to M/s Aventis and they have become absolute owner with no control of the Appellant - no service tax
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