Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Computation of Capital Gains - Exclusion of the portion of the sale consideration that was never received - The High court found that the real income (capital gains) should be computed based on the actual sale consideration received by the promoters, i.e., after deducting the amounts withdrawn from the escrow account for liabilities. It held that the initial computation, which included the escrow amount not received by the promoters, was incorrect. The full value of consideration for computing capital gains should reflect the actual amount received post-adjustments for liabilities.
Computation of Capital Gains - Exclusion of the portion of the sale consideration that was never received - The High court found that the real income (capital gains) should be computed based on the actual sale consideration received by the promoters, i.e., after deducting the amounts withdrawn from the escrow account for liabilities. It held that the initial computation, which included the escrow amount not received by the promoters, was incorrect. The full value of consideration for computing capital gains should reflect the actual amount received post-adjustments for liabilities.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
