Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
Development agreement for land development does not result in transfer u/s 2(47)(v) of the Act, and no capital gain is chargeable in the year of agreement; capital gain is taxable in the year when constructed area is given to the assessee. Addition of rental income accepted as income from house property. Loan received from daughter substantiated; loan from wife accepted considering negligible amount and spousal relationship. Unexplained addition of Rs. 90,237/- considered taxable; relief of Rs. 2,75,188/- granted. Cross-objection partly allowed.
Development agreement for land development does not result in transfer u/s 2(47)(v) of the Act, and no capital gain is chargeable in the year of agreement; capital gain is taxable in the year when constructed area is given to the assessee. Addition of rental income accepted as income from house property. Loan received from daughter substantiated; loan from wife accepted considering negligible amount and spousal relationship. Unexplained addition of Rs. 90,237/- considered taxable; relief of Rs. 2,75,188/- granted. Cross-objection partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
