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 ...
Determination of residential status and place of earning the income of the company - Sikkim or Delhi (India) - place of control and management at Delhi - the business conducted/done in Sikkim - The findings of fact recorded by the AO, confirmed by the CIT(A) that the control and management of the affairs of the assessee companies was with Auditor (CA) at Delhi are based on the entire material on record. - SC
Determination of residential status and place of earning the income of the company - Sikkim or Delhi (India) - place of control and management at Delhi - the business conducted/done in Sikkim - The findings of fact recorded by the AO, confirmed by the CIT(A) that the control and management of the affairs of the assessee companies was with Auditor (CA) at Delhi are based on the entire material on record. - SC
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