Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Computation of Period of holding - Transferable Development Rights(TDR) - for the purpose of determination of period of holding, the holding of the TDR from the date of acquisition of property by the municipal authorities has to be considered, not from the date, when MOU was cancelled, then the period of holding of the asset is more than 36 months and hence, surplus is rightly assessable under the head lTCG
Computation of Period of holding - Transferable Development Rights(TDR) - for the purpose of determination of period of holding, the holding of the TDR from the date of acquisition of property by the municipal authorities has to be considered, not from the date, when MOU was cancelled, then the period of holding of the asset is more than 36 months and hence, surplus is rightly assessable under the head lTCG
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
