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...
Validity of assessment order - mismatch between the GSTR 3B returns filed by the petitioner and the auto-populated GSTR 2A returns - The High court acknowledged the existence of difficulties arising from the mismatch between GSTR 3B and GSTR 2A returns, as evidenced by the issuance of Circular No.183. Despite the petitioner's non-participation in the assessment proceedings, the court considered the certificate from the Chartered Accountant provided by the petitioner and deemed it sufficient justification for interference with the impugned orders. - The court quashed the assessment orders and remanded the matters for reconsideration with the condition that the petitioner remits 10% of the disputed tax demand for each assessment period within 15 days.
Validity of assessment order - mismatch between the GSTR 3B returns filed by the petitioner and the auto-populated GSTR 2A returns - The High court acknowledged the existence of difficulties arising from the mismatch between GSTR 3B and GSTR 2A returns, as evidenced by the issuance of Circular No.183. Despite the petitioner's non-participation in the assessment proceedings, the court considered the certificate from the Chartered Accountant provided by the petitioner and deemed it sufficient justification for interference with the impugned orders. - The court quashed the assessment orders and remanded the matters for reconsideration with the condition that the petitioner remits 10% of the disputed tax demand for each assessment period within 15 days.
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