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...
Reopening of assessment u/s 147 - Deduction u/s 80IB(10) - built-up area of some of the residential units in the project was more than the prescribed area of 1000 sq. ft - the reopening of the case before us was carried out on the basis of fresh “tangible material” which clearly established that the A.O had a ‘reason to believe’ that the income of the assessee chargeable to tax had escaped assessment.
Reopening of assessment u/s 147 - Deduction u/s 80IB(10) - built-up area of some of the residential units in the project was more than the prescribed area of 1000 sq. ft - the reopening of the case before us was carried out on the basis of fresh “tangible material” which clearly established that the A.O had a ‘reason to believe’ that the income of the assessee chargeable to tax had escaped assessment.
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