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 in India - Royalty u/s. 9 and/or under Article- 12 of India - payments made in terms of Sponsorship Agreement - Singapore, DTAA - sponsorship of the ICC Cricket Events - such payments cannot be considered as royalty in the hands of recipient u/s. 9(1)(vi) - AT
Income taxable in India - Royalty u/s. 9 and/or under Article- 12 of India - payments made in terms of Sponsorship Agreement - Singapore, DTAA - sponsorship of the ICC Cricket Events - such payments cannot be considered as royalty in the hands of recipient u/s. 9(1)(vi) - AT
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