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...
Disallowance u/s. 14A - recording of satisfaction - AO before invoking Rule 8D has issued SCN to the assessee. The AO after considering the reply of assessee negated the same giving reasons and thereafter made disallowance under Rule 8D. AO has recorded his satisfaction as envisaged u/s. 14A(3)- disallowance upheld
Disallowance u/s. 14A - recording of satisfaction - AO before invoking Rule 8D has issued SCN to the assessee. The AO after considering the reply of assessee negated the same giving reasons and thereafter made disallowance under Rule 8D. AO has recorded his satisfaction as envisaged u/s. 14A(3)- disallowance upheld
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