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 ...
ITAT resolved a tax dispute involving a UK-based engineering consultancy firm's income from services rendered in India. The Tribunal determined that payments received for consulting engineering services constitute business income under Article 7 of India-UK DTAA, not Fees for Technical Services (FTS). Since the company lacked a Permanent Establishment in India, the income was deemed non-taxable in India. The Tribunal upheld the assessee's position, consistent with its prior decisions in similar cases, and allowed the appeal, effectively exempting the income from Indian taxation.
ITAT resolved a tax dispute involving a UK-based engineering consultancy firm's income from services rendered in India. The Tribunal determined that payments received for consulting engineering services constitute business income under Article 7 of India-UK DTAA, not Fees for Technical Services (FTS). Since the company lacked a Permanent Establishment in India, the income was deemed non-taxable in India. The Tribunal upheld the assessee's position, consistent with its prior decisions in similar cases, and allowed the appeal, effectively exempting the income from Indian taxation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
