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...
Power of High Court to entertain writ petition - alternative efficacious remedy u/s 129A - The court decided not to entertain the petitions on the basis of the alternative remedies available and the non-fulfillment of the requests for procedural rights not resulting in substantial prejudice that couldn't be remedied through the appeals process. The court dismissed the petitions but allowed the petitioners to appeal to the CESTAT, instructing the tribunal to consider their appeals without regard to the delay caused by the High Court proceedings.
Power of High Court to entertain writ petition - alternative efficacious remedy u/s 129A - The court decided not to entertain the petitions on the basis of the alternative remedies available and the non-fulfillment of the requests for procedural rights not resulting in substantial prejudice that couldn't be remedied through the appeals process. The court dismissed the petitions but allowed the petitioners to appeal to the CESTAT, instructing the tribunal to consider their appeals without regard to the delay caused by the High Court proceedings.
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