Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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Permanent Establishment in India - advertisement revenue - India-Mauritius DTAA - foreign company / Non-resident - Taj India cannot be held to be a DAPE of the assessee in India under Article 5(4)(i) of the India-Mauritius DTAA in respect of the same. - AT
Permanent Establishment in India - advertisement revenue - India-Mauritius DTAA - foreign company / Non-resident - Taj India cannot be held to be a DAPE of the assessee in India under Article 5(4)(i) of the India-Mauritius DTAA in respect of the same. - AT
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