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...
Rectification of mistake u/s 154 - withdrawing the interest granted to the assessee u/s. 244A - as it is noticed that the AO is not the authority who could attribute the delay in the issuance of the refund u/s 244A(2) as also on the ground that the issue is highly debatable issue, we are of the view that the order passed u/s. 154 is unsustainable - AT
Rectification of mistake u/s 154 - withdrawing the interest granted to the assessee u/s. 244A - as it is noticed that the AO is not the authority who could attribute the delay in the issuance of the refund u/s 244A(2) as also on the ground that the issue is highly debatable issue, we are of the view that the order passed u/s. 154 is unsustainable - AT
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