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 ...
Income taxable/attribuable in India - attributed 15% of the assessee’s income to India - applicability of the Galileo rule[2009 (2) TMI 497 - DELHI HIGH COURT] - Galileo Nederland BV [supra] has now merged with the order of this Court in Travelport [2023 (5) TMI 227 - SUPREME COURT] filed by the Revenue before this Court. - Revenue appeal dismissed - SC
Income taxable/attribuable in India - attributed 15% of the assessee’s income to India - applicability of the Galileo rule[2009 (2) TMI 497 - DELHI HIGH COURT] - Galileo Nederland BV [supra] has now merged with the order of this Court in Travelport [2023 (5) TMI 227 - SUPREME COURT] filed by the Revenue before this Court. - Revenue appeal dismissed - SC
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