E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
Prescribed transfer-pricing methods must govern arm's length price determination; an ad hoc allocation of consideration between independently negotiated business-transfer and intellectual-property agreements cannot be sustained without comparable analysis, valuation, benchmarking or another recognised methodology. Advertisement, marketing and promotion expenditure alone does not establish economic ownership of marketing intangibles or permit rewriting arm's length agreements absent sham or collusion. The transfer-pricing adjustment was deleted without remand. The dividend distribution tax treaty-rate claim was remitted for action dependent on pending Supreme Court proceedings. Interest for delayed return filing caused by an undisputed e-filing portal glitch was deleted, while the assessment-limitation challenge became infructuous following retrospective amendments.
Prescribed transfer-pricing methods must govern arm's length price determination; an ad hoc allocation of consideration between independently negotiated business-transfer and intellectual-property agreements cannot be sustained without comparable analysis, valuation, benchmarking or another recognised methodology. Advertisement, marketing and promotion expenditure alone does not establish economic ownership of marketing intangibles or permit rewriting arm's length agreements absent sham or collusion. The transfer-pricing adjustment was deleted without remand. The dividend distribution tax treaty-rate claim was remitted for action dependent on pending Supreme Court proceedings. Interest for delayed return filing caused by an undisputed e-filing portal glitch was deleted, while the assessment-limitation challenge became infructuous following retrospective amendments.
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TaxTMI 
TaxTMI 
of 4891 
