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...
Adjustment of "seized asset" against "existing liability" and levy of "interest u/s 234B" - outer time period of 120 days - The ITAT held that Ld AO miserably failed to adhere to the provisions of section 132B[1] and the CIT [A] is not justified in confirming the interest charged u/s. 234B of the Act for the period up to 15-09-2010. Therefore AO directed to rework the computation in accordance with the provisions of law after providing proper opportunity of hearing to the assessees. - However, ITAT the claim concerning the grant of interest on seized assets u/s 132B(4), agreeing with the lower authorities that FDRs do not qualify as "money" for the purpose of interest entitlement.
Adjustment of "seized asset" against "existing liability" and levy of "interest u/s 234B" - outer time period of 120 days - The ITAT held that Ld AO miserably failed to adhere to the provisions of section 132B[1] and the CIT [A] is not justified in confirming the interest charged u/s. 234B of the Act for the period up to 15-09-2010. Therefore AO directed to rework the computation in accordance with the provisions of law after providing proper opportunity of hearing to the assessees. - However, ITAT the claim concerning the grant of interest on seized assets u/s 132B(4), agreeing with the lower authorities that FDRs do not qualify as "money" for the purpose of interest entitlement.
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