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...
Rejection of declaration filed under the amnesty scheme - SVLDRS - SVLDR is a beneficial scheme and purposive interpretation of its terms is desirable - The declarants are thus expected to come clean in order take its benefit. During investigation, Petitioner only admitted Service Tax liability and did not make any disclosure with respect to the other tax dues and as a result whereof, after investigation, Respondents have issued the demand-cum show cause notice - This SCN would have to be adjudicated in entirety and cannot be done in a piecemeal manner - Petitioner's declaration was rightly rejected - HC
Rejection of declaration filed under the amnesty scheme - SVLDRS - SVLDR is a beneficial scheme and purposive interpretation of its terms is desirable - The declarants are thus expected to come clean in order take its benefit. During investigation, Petitioner only admitted Service Tax liability and did not make any disclosure with respect to the other tax dues and as a result whereof, after investigation, Respondents have issued the demand-cum show cause notice - This SCN would have to be adjudicated in entirety and cannot be done in a piecemeal manner - Petitioner's declaration was rightly rejected - HC
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