Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Taxable services - refrain from an act or agreed to tolerate any act - surrender of tenancy rights or benefits - the view of adjudicating authority that ‘capital gains’ can be earned only against change in ownership, not otherwise, cannot be agreed upon. It is now established law that any amount received on account of surrender of tenancy rights is also liable to capital gains tax as per the Income Tax Act, 1961. - By the surrender of the agreement rights in the property by the appellants it cannot be said that the appellants agreed to refrain from an act or agreed to tolerate any act of the eventual buyer or tolerated any act or situation. - AT
Taxable services - refrain from an act or agreed to tolerate any act - surrender of tenancy rights or benefits - the view of adjudicating authority that ‘capital gains’ can be earned only against change in ownership, not otherwise, cannot be agreed upon. It is now established law that any amount received on account of surrender of tenancy rights is also liable to capital gains tax as per the Income Tax Act, 1961. - By the surrender of the agreement rights in the property by the appellants it cannot be said that the appellants agreed to refrain from an act or agreed to tolerate any act of the eventual buyer or tolerated any act or situation. - AT
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