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 ...
Royalty receipt - transfer of right to use a computer software - The Judgement by the Appellate Tribunal addressed the dispute regarding the classification of income and the applicable tax rate for the appellant. The Tribunal found in favor of the appellant, ruling that the income received should be considered royalty income under Sec. 9(1)(vi) of the Act and taxed at 10%.
Royalty receipt - transfer of right to use a computer software - The Judgement by the Appellate Tribunal addressed the dispute regarding the classification of income and the applicable tax rate for the appellant. The Tribunal found in favor of the appellant, ruling that the income received should be considered royalty income under Sec. 9(1)(vi) of the Act and taxed at 10%.
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