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...
Condonation of delay - delay of 309 days - The Court cannot be oblivious to the fact that departmental appeals involve unavoidable procedural delays by reason of pushing of files from one authority to the other, obtaining of the requisite clearances and the like, and a month’s time for preparation of the appeal and connected ground work for filing the appeal is not unreasonable - HC
Condonation of delay - delay of 309 days - The Court cannot be oblivious to the fact that departmental appeals involve unavoidable procedural delays by reason of pushing of files from one authority to the other, obtaining of the requisite clearances and the like, and a month’s time for preparation of the appeal and connected ground work for filing the appeal is not unreasonable - HC
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