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 ...
Insurance Auxiliary Services - brokerage received from overseas reinsurance - Export of service or not - Non receipt of consideration in foreign exchange - the basis of the circular, which is clarified that Notification Nos. 6/99, 9/01, 13/02 and 2/03 would not apply to export of service, the question of receiving the payment in convertible foreign exchange does not arise. Even the Export of Service Rules, 2005 does not put an embargo in relation to taxable service as specified in Rule 3(3)(i), (ii) and (iii) of the Export of Service Rules.
Insurance Auxiliary Services - brokerage received from overseas reinsurance - Export of service or not - Non receipt of consideration in foreign exchange - the basis of the circular, which is clarified that Notification Nos. 6/99, 9/01, 13/02 and 2/03 would not apply to export of service, the question of receiving the payment in convertible foreign exchange does not arise. Even the Export of Service Rules, 2005 does not put an embargo in relation to taxable service as specified in Rule 3(3)(i), (ii) and (iii) of the Export of Service Rules.
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