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...
TDS u/s 195 - Royalty - purchase of software - Considering the Assessee was granted a distributorship/license to sell the products manufactured by the MGI, with a condition not to make or assign any copyright therein and while reserving all rights including ownership of material with it, goes to show that the transaction between the Assessee and the MGI cannot be termed as ‘ROYALTY’ - AT
TDS u/s 195 - Royalty - purchase of software - Considering the Assessee was granted a distributorship/license to sell the products manufactured by the MGI, with a condition not to make or assign any copyright therein and while reserving all rights including ownership of material with it, goes to show that the transaction between the Assessee and the MGI cannot be termed as ‘ROYALTY’ - AT
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