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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Taxability of income in India - Addition of receipt emanating from offshore supplies of escalators and elevators - The Appellate Tribunal observed that the consortium, comprising the appellant and another entity, had distinct and separate responsibilities delineated in the Memorandum of Understanding (MOU). The Tribunal emphasized that the income accrued to the appellant from offshore supplies, and as per relevant legal precedents, such income was not taxable in India. Therefore, the Tribunal directed the assessing officer to delete the addition made to the appellant's income.
Taxability of income in India - Addition of receipt emanating from offshore supplies of escalators and elevators - The Appellate Tribunal observed that the consortium, comprising the appellant and another entity, had distinct and separate responsibilities delineated in the Memorandum of Understanding (MOU). The Tribunal emphasized that the income accrued to the appellant from offshore supplies, and as per relevant legal precedents, such income was not taxable in India. Therefore, the Tribunal directed the assessing officer to delete the addition made to the appellant's income.
Note: It is a system-generated summary and is for quick reference only.