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...
Land executed under a development agreement-cum-power of attorney was held assessable in the individual owners' hands because legal title vested in them and the documents were executed by them personally, while the asserted partition was treated only as an internal family arrangement and not proof of HUF ownership. The Tribunal further held that the agreement granted the developer only a limited licence to enter for construction, not effective transfer of possession for capital gains purposes, and no non-refundable consideration had been received. As the essential conditions for transfer were not satisfied in the relevant year, the capital gains addition was deleted.
Land executed under a development agreement-cum-power of attorney was held assessable in the individual owners' hands because legal title vested in them and the documents were executed by them personally, while the asserted partition was treated only as an internal family arrangement and not proof of HUF ownership. The Tribunal further held that the agreement granted the developer only a limited licence to enter for construction, not effective transfer of possession for capital gains purposes, and no non-refundable consideration had been received. As the essential conditions for transfer were not satisfied in the relevant year, the capital gains addition was deleted.
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