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Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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Assessment u/s 153A - Validity of search proceedings - validity of the order of transfer passed u/s 127 - The ground taken by the petitioner of pendency of the litigation in the Allahabad High Court is of no assistance since the cause raised therein is regarding legality and validity of the order of transfer passed u/s 127 of the IT Act. Assuming without admitting that the said petition is allowed by the Allahabad High Court, even then the search and seizure operation which led to the passing of impugned order herein would not be adversely affected. More so, Allahabad High Court has not granted any interim order in favour of the petitioner. - HC
Assessment u/s 153A - Validity of search proceedings - validity of the order of transfer passed u/s 127 - The ground taken by the petitioner of pendency of the litigation in the Allahabad High Court is of no assistance since the cause raised therein is regarding legality and validity of the order of transfer passed u/s 127 of the IT Act. Assuming without admitting that the said petition is allowed by the Allahabad High Court, even then the search and seizure operation which led to the passing of impugned order herein would not be adversely affected. More so, Allahabad High Court has not granted any interim order in favour of the petitioner. - HC
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