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 - Royalty and FTS payment for non deduction of TDS - Co-location services and connectivity services provided for the process of connecting by the assessee with the various customers towards making voice and data connectivity - the consideration being for the use and the right to use of the process, it is 'royalty' within the meaning of Clause (iii) of Explanation 2 to Section 9(1)(vi) of the Income Tax Act - AT
TDS u/s 195 - Royalty and FTS payment for non deduction of TDS - Co-location services and connectivity services provided for the process of connecting by the assessee with the various customers towards making voice and data connectivity - the consideration being for the use and the right to use of the process, it is 'royalty' within the meaning of Clause (iii) of Explanation 2 to Section 9(1)(vi) of the Income Tax Act - AT
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