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...
Reopening of earlier orders of ITAT for making additions towards delayed payment of employee’s contribution to ESI and PF - if the Apex Court intended its judgment to be applied prospectively, it would have provided a specific rider - as no such rider is found in the Checkmate Services Pvt. Ltd. vs. Commissioner of Income Tax-I case, it is concluded that the judgment has retrospective application - ITAT recall the respective orders - Appeals filed by the revenue allowed - AT
Reopening of earlier orders of ITAT for making additions towards delayed payment of employee’s contribution to ESI and PF - if the Apex Court intended its judgment to be applied prospectively, it would have provided a specific rider - as no such rider is found in the Checkmate Services Pvt. Ltd. vs. Commissioner of Income Tax-I case, it is concluded that the judgment has retrospective application - ITAT recall the respective orders - Appeals filed by the revenue allowed - AT
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