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TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
SVLDRS - whether the excess disputed amount deposited by the petitioner by way of pre-deposit in respect of the first show-cause notice (SCN-1) can be adjusted towards the amount payable by the petitioner in respect of the second show-cause notice (SCN-2) under the SVLDRS. - The contention of the respondents that two separate show-cause notices cannot be clubbed together for the purpose of SVLDRS cannot be accepted especially when the respondents have given the benefits/relief under the SVLDRS in favour of the petitioner in respect of both the show-cause notices. - HC
SVLDRS - whether the excess disputed amount deposited by the petitioner by way of pre-deposit in respect of the first show-cause notice (SCN-1) can be adjusted towards the amount payable by the petitioner in respect of the second show-cause notice (SCN-2) under the SVLDRS. - The contention of the respondents that two separate show-cause notices cannot be clubbed together for the purpose of SVLDRS cannot be accepted especially when the respondents have given the benefits/relief under the SVLDRS in favour of the petitioner in respect of both the show-cause notices. - HC
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