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...
Long term capital gain - sub-tenancy right - the assessee had a sub-tenancy right in the property and upon surrender thereof, the assessee received a sum which was rightly offered as long-term capital gain in terms of section 45(1), 48, 55(2) and 2(29B) of the Income-tax Act, 1961. AO was wrong in rejecting the claim of long-term capital gain and assessing the same as income from other sources. - AT
Long term capital gain - sub-tenancy right - the assessee had a sub-tenancy right in the property and upon surrender thereof, the assessee received a sum which was rightly offered as long-term capital gain in terms of section 45(1), 48, 55(2) and 2(29B) of the Income-tax Act, 1961. AO was wrong in rejecting the claim of long-term capital gain and assessing the same as income from other sources. - AT
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