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...
GTA Service - denial of benefit of 75% abatement in the absence of any declaration furnished by the transport agencies - There is no merit in the submissions that even without declaration as stipulated in the notification, the assessee was entitled to such exemption, is over simplifying or glossing over the conditions itself, which cannot be permitted. - Tribunal was perfectly justified in denying such exemption.
GTA Service - denial of benefit of 75% abatement in the absence of any declaration furnished by the transport agencies - There is no merit in the submissions that even without declaration as stipulated in the notification, the assessee was entitled to such exemption, is over simplifying or glossing over the conditions itself, which cannot be permitted. - Tribunal was perfectly justified in denying such exemption.
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