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...
Reassessment u/s 147 - proceedings after expiry of 6 years - direction by court or mere observation - AO applied the provisions of section 150, when the findings of the coordinate bench are not direction but observation - proceedings initiated u/s 147 beyond 6 years are void ab-initio as per the time limit prescribed u/s 149 - assessment order quashed
Reassessment u/s 147 - proceedings after expiry of 6 years - direction by court or mere observation - AO applied the provisions of section 150, when the findings of the coordinate bench are not direction but observation - proceedings initiated u/s 147 beyond 6 years are void ab-initio as per the time limit prescribed u/s 149 - assessment order quashed
Note: It is a system-generated summary and is for quick reference only.