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 ...
Taxability of receipts from offshore supply of equipments - offshore supply made to Indian PSU’s which the assessee had claimed to be not chargeable to tax under Indian Taxation - Assessee company is tax resident of China - The Tribunal analyzed the terms of the contracts and previous tribunal decisions, which indicated that the transfer of title over the goods occurred outside India, making the receipts non-taxable in India. The court emphasized that the Assessing Officer's bifurcation lacked a rational basis and evidence, rendering it impermissible.
Taxability of receipts from offshore supply of equipments - offshore supply made to Indian PSU’s which the assessee had claimed to be not chargeable to tax under Indian Taxation - Assessee company is tax resident of China - The Tribunal analyzed the terms of the contracts and previous tribunal decisions, which indicated that the transfer of title over the goods occurred outside India, making the receipts non-taxable in India. The court emphasized that the Assessing Officer's bifurcation lacked a rational basis and evidence, rendering it impermissible.
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