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 ...
Business Auxiliary Services - promotion or marketing of goods produced or provided by or belonging to the client - transfer of right to use - The imposition of restrictions or conditions in respect of the usage and consumption of the concentrate, by the seller cannot alter that position. Hence there are no merit in the submission that this transaction was not a truncation of sale but only “transfer to use”. - AT
Business Auxiliary Services - promotion or marketing of goods produced or provided by or belonging to the client - transfer of right to use - The imposition of restrictions or conditions in respect of the usage and consumption of the concentrate, by the seller cannot alter that position. Hence there are no merit in the submission that this transaction was not a truncation of sale but only “transfer to use”. - AT
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