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 ...
Clarification provided that custodial services provided by banks or financial institutions to Foreign Portfolio Investors (FPIs) are not treated as services provided to 'account holder' u/s 13(8)(a) of IGST Act. Such services are not covered u/s 13(8)(a). Place of supply of custodial services to FPIs is to be determined under default provision i.e. sub-section (2) of Section 13 of IGST Act, not u/s 13(8)(a).
Clarification provided that custodial services provided by banks or financial institutions to Foreign Portfolio Investors (FPIs) are not treated as services provided to 'account holder' u/s 13(8)(a) of IGST Act. Such services are not covered u/s 13(8)(a). Place of supply of custodial services to FPIs is to be determined under default provision i.e. sub-section (2) of Section 13 of IGST Act, not u/s 13(8)(a).
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