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 - As been emphasized by the CBDT that the pending assessment and litigations should be handled taking into consideration the clarification so issued and in the instant case, a fresh litigation has been started by the Department by initiation of action u/s 263 which is clearly in the teeth of the CBDT Circular and cannot be sustained in the eyes of law. - AT
Revision u/s 263 - As been emphasized by the CBDT that the pending assessment and litigations should be handled taking into consideration the clarification so issued and in the instant case, a fresh litigation has been started by the Department by initiation of action u/s 263 which is clearly in the teeth of the CBDT Circular and cannot be sustained in the eyes of law. - AT
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TaxTMI 
TaxTMI 
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