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 ...
The case involved reimbursement of expenses u/s 195 of the Income Tax Act, concerning payments made for services rendered outside India. The payments to various entities were found to fall under exclusionary provisions of Section 9(1)(vii)(b), as they were for earning income from a source outside India. Disallowance u/s 40(a)(i) was deemed unwarranted and ordered to be deleted. Transactions with Carnegie Mellon University, Call Centre School LLC, APM Group, British Computer Society, RADTAC, and an individual for professional services were similarly analyzed and disallowances were overturned, citing legal provisions and tax residency status. The ITAT allowed the appeals of the assessee in all instances.
The case involved reimbursement of expenses u/s 195 of the Income Tax Act, concerning payments made for services rendered outside India. The payments to various entities were found to fall under exclusionary provisions of Section 9(1)(vii)(b), as they were for earning income from a source outside India. Disallowance u/s 40(a)(i) was deemed unwarranted and ordered to be deleted. Transactions with Carnegie Mellon University, Call Centre School LLC, APM Group, British Computer Society, RADTAC, and an individual for professional services were similarly analyzed and disallowances were overturned, citing legal provisions and tax residency status. The ITAT allowed the appeals of the assessee in all instances.
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