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 on payment of secondment cost - The assessee has reimbursed the salary cost of seconded employees on cost-to-cost basis without any profit element. The assessee has duly deducted tax at source from these payments u/s 192 - The stated employees have worked under the supervision and control of the assessee. - No further requirement of deduction of TDS u/s 195 - AT
TDS u/s 195 on payment of secondment cost - The assessee has reimbursed the salary cost of seconded employees on cost-to-cost basis without any profit element. The assessee has duly deducted tax at source from these payments u/s 192 - The stated employees have worked under the supervision and control of the assessee. - No further requirement of deduction of TDS u/s 195 - AT
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