Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
TPA - ALP of umbrella of services - Non-availing of services cannot be the basis for rejecting the claim - TPO or the DRP has not stated that payment made by the assessee to its AE were not at Arm’s length.
TPA - ALP of umbrella of services - Non-availing of services cannot be the basis for rejecting the claim - TPO or the DRP has not stated that payment made by the assessee to its AE were not at Arm’s length.
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