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 ...
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Transfer pricing disputes resolved under the India-Japan MAP can be given effect only after the assessee withdraws the appeal ground covered by the resolution. Article 25 of the treaty was invoked for the transaction with Japanese associated enterprises, and the assessee stated that it would accept the competent authorities' resolution. Under Rule 44G, the Assessing Officer is to pass orders giving effect to the MAP resolution once the related appeal is withdrawn. The assessee accordingly requested withdrawal of the relevant ground, and the tax department raised no objection.
Transfer pricing disputes resolved under the India-Japan MAP can be given effect only after the assessee withdraws the appeal ground covered by the resolution. Article 25 of the treaty was invoked for the transaction with Japanese associated enterprises, and the assessee stated that it would accept the competent authorities' resolution. Under Rule 44G, the Assessing Officer is to pass orders giving effect to the MAP resolution once the related appeal is withdrawn. The assessee accordingly requested withdrawal of the relevant ground, and the tax department raised no objection.
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