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 ...
Location of supplier and 'place of business' depend on where the supplier ordinarily runs the business; therefore the place from which supplies are made determines the location of services - outcome: services are located at the Head Office (HO). Whether FSEs constitute an agent or create a place of business was addressed by noting FSEs are employees who do not contract with customers independently and can be withdrawn by the HO - outcome: FSE presence in Odisha is not a separate place of business or fixed establishment. Registration liability follows the supplier location; outcome: no separate GST registration required in Odisha.
Location of supplier and 'place of business' depend on where the supplier ordinarily runs the business; therefore the place from which supplies are made determines the location of services - outcome: services are located at the Head Office (HO). Whether FSEs constitute an agent or create a place of business was addressed by noting FSEs are employees who do not contract with customers independently and can be withdrawn by the HO - outcome: FSE presence in Odisha is not a separate place of business or fixed establishment. Registration liability follows the supplier location; outcome: no separate GST registration required in Odisha.
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