Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Clause 10(e) of the CBDT circular on low-tax-effect appeals was construed as an exception covering enforcement agencies akin to CBI, ED, DRI, SFIO and DGGI, rather than those names alone. On that interpretation, the VAT department was treated as falling within the exception because it functioned as an enforcement agency. The Tribunal therefore misread the circular by excluding VAT merely because it was not expressly named. The order rejecting the Revenue's rectification application was set aside, and the matter was restored to the Tribunal for decision on merits after hearing both sides.
Clause 10(e) of the CBDT circular on low-tax-effect appeals was construed as an exception covering enforcement agencies akin to CBI, ED, DRI, SFIO and DGGI, rather than those names alone. On that interpretation, the VAT department was treated as falling within the exception because it functioned as an enforcement agency. The Tribunal therefore misread the circular by excluding VAT merely because it was not expressly named. The order rejecting the Revenue's rectification application was set aside, and the matter was restored to the Tribunal for decision on merits after hearing both sides.
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