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 - limited scrutiny assessment - Based on the information mentioned in the revisionary order, the learned PCIT should have reprimanded the assessing officer by asking assessee to furnish the information, which were not within the scope of limited scrutiny. Instead of that, PCIT has invoked the provisions of Section 263 on such information. - AT
Revision u/s 263 by CIT - limited scrutiny assessment - Based on the information mentioned in the revisionary order, the learned PCIT should have reprimanded the assessing officer by asking assessee to furnish the information, which were not within the scope of limited scrutiny. Instead of that, PCIT has invoked the provisions of Section 263 on such information. - AT
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