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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Income taxable in India - royalty receipts - Distribution of Financial Products - assessee had granted rights to distribute its various financial and related products in the Indian market to DJCIPL on a principal to principal basis and at arm’s length price. - purchase price of Factiva products distributed by DJCIPL is not taxable as ‘royalty’ under India UK DTAA in the hands of the assessee. - AT
Income taxable in India - royalty receipts - Distribution of Financial Products - assessee had granted rights to distribute its various financial and related products in the Indian market to DJCIPL on a principal to principal basis and at arm’s length price. - purchase price of Factiva products distributed by DJCIPL is not taxable as ‘royalty’ under India UK DTAA in the hands of the assessee. - AT
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