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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
A timely filed rectification application remains capable of decision on merits after the three-month disposal timeline expires. The requirement that the competent authority decide the application "as far as possible" within that period is directory: it requires an endeavour to comply but neither makes the authority functus officio nor removes its jurisdiction after three months. Rejection solely on the ground that the disposal period had expired was quashed, and the application was remitted for a merits-based decision within three months.
A timely filed rectification application remains capable of decision on merits after the three-month disposal timeline expires. The requirement that the competent authority decide the application "as far as possible" within that period is directory: it requires an endeavour to comply but neither makes the authority functus officio nor removes its jurisdiction after three months. Rejection solely on the ground that the disposal period had expired was quashed, and the application was remitted for a merits-based decision within three months.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
