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 ...
Entitlement to benefits of treaty exemption - India-Singapore DTAA - Application of Section 172 - Taxation of shipping companies - The tribunal concluded that the arguments regarding the denial of tax treaty benefits and the condition of remittance required a re-evaluation of the evidence, particularly the letter from IRAS. Given the discrepancies and the need for further clarification, the tribunal remanded the matter to the Assessing Officer for detailed verification of the IRAS certificate and its implications on the assessee's tax liability under the India-Singapore DTAA.
Entitlement to benefits of treaty exemption - India-Singapore DTAA - Application of Section 172 - Taxation of shipping companies - The tribunal concluded that the arguments regarding the denial of tax treaty benefits and the condition of remittance required a re-evaluation of the evidence, particularly the letter from IRAS. Given the discrepancies and the need for further clarification, the tribunal remanded the matter to the Assessing Officer for detailed verification of the IRAS certificate and its implications on the assessee's tax liability under the India-Singapore DTAA.
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