Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Service Tax liability and Pre-deposit - The Supreme Court held that Section 35 of FEMA confers the right of appeal to any person aggrieved by "any order" or decision of the Appellate Tribunal, subject to limitations. Section 35G allows appeals to the High Court from "every order" of the Tribunal, with statutory restrictions. An order need not adjudicate on parties' rights to qualify for appeal. Statutory limitations do not render an order non-appealable. Writ petition not entertained due to alternative remedy and lack of territorial jurisdiction, preventing bypassing of statutory provisions. Petition dismissed. (HC = High Court)
Service Tax liability and Pre-deposit - The Supreme Court held that Section 35 of FEMA confers the right of appeal to any person aggrieved by "any order" or decision of the Appellate Tribunal, subject to limitations. Section 35G allows appeals to the High Court from "every order" of the Tribunal, with statutory restrictions. An order need not adjudicate on parties' rights to qualify for appeal. Statutory limitations do not render an order non-appealable. Writ petition not entertained due to alternative remedy and lack of territorial jurisdiction, preventing bypassing of statutory provisions. Petition dismissed. (HC = High Court)
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