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...
Addition u/s 69 - unexplained investment - share transactions - Year of assessment - the transaction for legal transfer of shares actually took place in the subsequent assessment year but not in the year under consideration. - Thus addition cannot be sustained merely on assumption and presumption where the evidence clearly supports the contention of the assessee. - AT
Addition u/s 69 - unexplained investment - share transactions - Year of assessment - the transaction for legal transfer of shares actually took place in the subsequent assessment year but not in the year under consideration. - Thus addition cannot be sustained merely on assumption and presumption where the evidence clearly supports the contention of the assessee. - AT
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