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...
Terming the appellant as a risky exporter and a tag being fixed - The process of adjudication is quite distinct and different from terming a person a risky exporter, which tag cannot be perpetually affixed to an exporter as it would tantamount to interfering with his right to carry on exports based on suspicion. Therefore, the representation dated 10th March, 2022 should be considered by the sixth respondent within the timeline stipulated by this Court. - HC
Terming the appellant as a risky exporter and a tag being fixed - The process of adjudication is quite distinct and different from terming a person a risky exporter, which tag cannot be perpetually affixed to an exporter as it would tantamount to interfering with his right to carry on exports based on suspicion. Therefore, the representation dated 10th March, 2022 should be considered by the sixth respondent within the timeline stipulated by this Court. - HC
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TaxTMI 
TaxTMI 
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