Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Statutory appellate jurisdiction over refusal of court-ordered interim measures remains exclusively with the court designated under the Arbitration and Conciliation Act. An Arbitral Tribunal's power to grant interim measures cannot be converted into appellate jurisdiction over a court's interim-measure order, even with party consent. Accordingly, remitting a pending statutory appeal to a subsequently constituted Tribunal for treatment as an interim-measures application was set aside. Following the Tribunal's constitution, parties may independently seek legally available interim protection before it, while remaining disputes proceed to arbitration.
Statutory appellate jurisdiction over refusal of court-ordered interim measures remains exclusively with the court designated under the Arbitration and Conciliation Act. An Arbitral Tribunal's power to grant interim measures cannot be converted into appellate jurisdiction over a court's interim-measure order, even with party consent. Accordingly, remitting a pending statutory appeal to a subsequently constituted Tribunal for treatment as an interim-measures application was set aside. Following the Tribunal's constitution, parties may independently seek legally available interim protection before it, while remaining disputes proceed to arbitration.
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