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 ...
TDS u/s 195 - use of logo - license fee payment without deducting TDS SUPIMA, USA - Agreement clearly shows that the payment is made by the assessee to use the Logo of SUPIMA(R) and therefore, it is a payment of royalty. In so far as the other argument of the assessee is that the payment is made every year, in our opinion, whether the payment is made once or payment is made every year does not make any difference. - AO has rightly invoked Section 195 - AT
TDS u/s 195 - use of logo - license fee payment without deducting TDS SUPIMA, USA - Agreement clearly shows that the payment is made by the assessee to use the Logo of SUPIMA(R) and therefore, it is a payment of royalty. In so far as the other argument of the assessee is that the payment is made every year, in our opinion, whether the payment is made once or payment is made every year does not make any difference. - AO has rightly invoked Section 195 - AT
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