Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
The ITAT ruled that the transfer of booking rights in a capital asset was completed in AY 2009-10, not AY 2008-09. The agreement to sell was contingent on builder's permission granted in 2008. Therefore, the capital gain addition in AY 2008-09 was deleted, and in AY 2009-10, it was converted from protective to substantive basis. The assessee's grounds were allowed.
The ITAT ruled that the transfer of booking rights in a capital asset was completed in AY 2009-10, not AY 2008-09. The agreement to sell was contingent on builder's permission granted in 2008. Therefore, the capital gain addition in AY 2008-09 was deleted, and in AY 2009-10, it was converted from protective to substantive basis. The assessee's grounds were allowed.
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