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...
Proceedings before the CIT after transfer / posting - proceedings are continuous, merely because on change of incumbent, fresh show cause notice was issued, it cannot be construed to mean that it is fresh show cause notice especially in view of the fact that there is no evidence on record to show that earlier show cause notice was dropped. Thus, the appellant himself is responsible for delay in culminating the proceedings into the final order. Appeal filed by the assessee is dismissed. - AT
Proceedings before the CIT after transfer / posting - proceedings are continuous, merely because on change of incumbent, fresh show cause notice was issued, it cannot be construed to mean that it is fresh show cause notice especially in view of the fact that there is no evidence on record to show that earlier show cause notice was dropped. Thus, the appellant himself is responsible for delay in culminating the proceedings into the final order. Appeal filed by the assessee is dismissed. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
