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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Capital gain arising on transfer of land - STCG arising out of the transfer of non-agricultural land - real owner - The appellant asserts that the land was purchased on behalf of the company, as evidenced by a development agreement executed between the appellant and the company. However, the Tribunal finds no explicit indication in the documents that the appellant was authorized by the company to purchase the land on its behalf. The absence of a memorandum of understanding or any explicit authorization leads the Tribunal to conclude that the land was purchased by the appellant individually, not on behalf of the company.
Capital gain arising on transfer of land - STCG arising out of the transfer of non-agricultural land - real owner - The appellant asserts that the land was purchased on behalf of the company, as evidenced by a development agreement executed between the appellant and the company. However, the Tribunal finds no explicit indication in the documents that the appellant was authorized by the company to purchase the land on its behalf. The absence of a memorandum of understanding or any explicit authorization leads the Tribunal to conclude that the land was purchased by the appellant individually, not on behalf of the company.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
