Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
For capital gains purposes, the Tribunal treated the property as a long-term capital asset because the assessee had paid the full consideration and obtained possession and enjoyment in FY 2013-14; the later formal registration did not control the holding period. On that factual basis, indexation was allowed from FY 2013-14 and the gain was not assessed as short-term capital gain. The Tribunal also accepted registration charges paid in September 2013 as part of the cost of acquisition, since the supporting documents were unchallenged and there was no material to show duplication. The Revenue's appeal was dismissed and the additions were deleted.
For capital gains purposes, the Tribunal treated the property as a long-term capital asset because the assessee had paid the full consideration and obtained possession and enjoyment in FY 2013-14; the later formal registration did not control the holding period. On that factual basis, indexation was allowed from FY 2013-14 and the gain was not assessed as short-term capital gain. The Tribunal also accepted registration charges paid in September 2013 as part of the cost of acquisition, since the supporting documents were unchallenged and there was no material to show duplication. The Revenue's appeal was dismissed and the additions were deleted.
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