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...
Cessation of liability u/s 41(1) - Notice issued u/s 133(6) could not be served upon the creditors - while the assessee has continued to declare the trading liability in its books of account, no benefit can be said to have been obtained in respect of such trading liability by way of remission or cessation thereof and thus the requirement of Section 41(1) are not satisfied - The additions made u/s 41(1) set aside and reversed. - AT
Cessation of liability u/s 41(1) - Notice issued u/s 133(6) could not be served upon the creditors - while the assessee has continued to declare the trading liability in its books of account, no benefit can be said to have been obtained in respect of such trading liability by way of remission or cessation thereof and thus the requirement of Section 41(1) are not satisfied - The additions made u/s 41(1) set aside and reversed. - AT
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