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...
Valuation - Import of software - mode of import of software - BSNL being a Government Company, which cannot be alleged that they have colluded with the appellant in erroneously splitting the value of the hardware and software component - Demand confirmed, penalty set aside.
Valuation - Import of software - mode of import of software - BSNL being a Government Company, which cannot be alleged that they have colluded with the appellant in erroneously splitting the value of the hardware and software component - Demand confirmed, penalty set aside.
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