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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Tax deduction at source remained mandatory, and interim protection against withholding was refused because no finding had been made that the payments were not chargeable to tax; the Court would not bypass statutory deduction on equitable grounds or by substituting security. To end the continuing uncertainty for the non-resident taxpayer, the pending advance ruling applications were treated as withdrawn, and the Assessing Officer was directed to complete the A.Y. 2018-19 assessment while examining taxability under the Act, the DTAA, and the equalisation levy implications.
Tax deduction at source remained mandatory, and interim protection against withholding was refused because no finding had been made that the payments were not chargeable to tax; the Court would not bypass statutory deduction on equitable grounds or by substituting security. To end the continuing uncertainty for the non-resident taxpayer, the pending advance ruling applications were treated as withdrawn, and the Assessing Officer was directed to complete the A.Y. 2018-19 assessment while examining taxability under the Act, the DTAA, and the equalisation levy implications.
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