Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
TP Adjustment - interest on delayed receivables - Assessee pleaded that the deferred receivables do not constitute a separate international transaction requiring benchmarking and such a treatment is bad under law and working capital adjustment would take into account the impact of outstanding receivables and no need to impute any interest on receivables - the interest shall be charged only at 6% p.a. in respect of the receivables outstanding for more than 30 days. - AT
TP Adjustment - interest on delayed receivables - Assessee pleaded that the deferred receivables do not constitute a separate international transaction requiring benchmarking and such a treatment is bad under law and working capital adjustment would take into account the impact of outstanding receivables and no need to impute any interest on receivables - the interest shall be charged only at 6% p.a. in respect of the receivables outstanding for more than 30 days. - AT
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