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...
Benami transaction - The petitioner argues that the transactions in question occurred before the amendment of the Act in 2016, making the notice and order invalid. They rely on Supreme Court judgments and decisions of appellate tribunals and other High Courts to support their position. - The High Court, however, finds that the show cause notice and provisional attachment order are provisional in nature and subject to judicial review by the adjudicating authority. It declines to entertain the petitions at this stage, emphasizing the availability of statutory alternative remedies.
Benami transaction - The petitioner argues that the transactions in question occurred before the amendment of the Act in 2016, making the notice and order invalid. They rely on Supreme Court judgments and decisions of appellate tribunals and other High Courts to support their position. - The High Court, however, finds that the show cause notice and provisional attachment order are provisional in nature and subject to judicial review by the adjudicating authority. It declines to entertain the petitions at this stage, emphasizing the availability of statutory alternative remedies.
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