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 ...
Royalty income earned from the OEMs on network equipment -In view of the specific clauses in the agreement between OEM's and Indian parties, it is clear that the software didn't have an independent use and is a integral part of the hardware without which the hardware cannot function. The software supplied was a copyrighted article and not a copyright right - Not taxable u/s 9 - AT
Royalty income earned from the OEMs on network equipment -In view of the specific clauses in the agreement between OEM's and Indian parties, it is clear that the software didn't have an independent use and is a integral part of the hardware without which the hardware cannot function. The software supplied was a copyrighted article and not a copyright right - Not taxable u/s 9 - AT
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