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 accrued in India - engineering package fee and on-site man-day charges - the service rendered by the assessee is in connection with installation/erection of plant and machinery involved in mining of natural resources - Scope of Article 5(2)(g) of India-Portugal DTAA is not merely limited to mining or extraction of natural resources but also covers installation or structure used for exploration and exploitation of nature resources. - The amount paid would not qualify as FTS. - Demand set aside - AT
Income accrued in India - engineering package fee and on-site man-day charges - the service rendered by the assessee is in connection with installation/erection of plant and machinery involved in mining of natural resources - Scope of Article 5(2)(g) of India-Portugal DTAA is not merely limited to mining or extraction of natural resources but also covers installation or structure used for exploration and exploitation of nature resources. - The amount paid would not qualify as FTS. - Demand set aside - AT
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