Fair market value under section 50C must reflect existing property condition, not hypothetical development, and statutory valuation steps must be foll...
Compensation received on termination of network participation agreement from Citibank - Income deemed to accrue or arise in India - received does not fit into any of the definition of royalty either under IT Act or as per DTAA - it falls u/s.28(va)(b) as the business receipt and As per Article 7 of Indo-US DTAA, same is taxable only in USA and not in India - matter however, remanded to inquire for existence of PE in India
Compensation received on termination of network participation agreement from Citibank - Income deemed to accrue or arise in India - received does not fit into any of the definition of royalty either under IT Act or as per DTAA - it falls u/s.28(va)(b) as the business receipt and As per Article 7 of Indo-US DTAA, same is taxable only in USA and not in India - matter however, remanded to inquire for existence of PE in India
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