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...
Revision u/s 263 by CIT - addition u/s 40A ignored by AO - expenses have been incurred in cash exceeding Rs. 20,000/- per day - AO is expected to examine the provisions of section 40A(3) vis-à-vis respective transactions and determine which all these transactions are covered by the provisions of section 40A(3) and which all transactions fall under the exception as so provided in the Rule 6DD and decide accordingly. - AO has failed to examine and invoke at first place - Revision sustained - AT
Revision u/s 263 by CIT - addition u/s 40A ignored by AO - expenses have been incurred in cash exceeding Rs. 20,000/- per day - AO is expected to examine the provisions of section 40A(3) vis-à-vis respective transactions and determine which all these transactions are covered by the provisions of section 40A(3) and which all transactions fall under the exception as so provided in the Rule 6DD and decide accordingly. - AO has failed to examine and invoke at first place - Revision sustained - AT
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