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...
Best judgment assessment u/s 144 - addition u/s 68 - The learned CIT(A) ought to have stepped into shoes of the AO to compute income chargeable to tax due to non co-operation of assessee in assessment - It was also incumbent on CIT(A) to have looked into applicability of provisions of Section 56(2)(viia) to transaction for purchase of equity shares - CIT(A) order set aside
Best judgment assessment u/s 144 - addition u/s 68 - The learned CIT(A) ought to have stepped into shoes of the AO to compute income chargeable to tax due to non co-operation of assessee in assessment - It was also incumbent on CIT(A) to have looked into applicability of provisions of Section 56(2)(viia) to transaction for purchase of equity shares - CIT(A) order set aside
Note: It is a system-generated summary and is for quick reference only.