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...
Multiple show cause notices issued with overlapping discrepancies, resulting in confusion and lack of opportunity for petitioner to respond adequately. Impugned order passed without considering circumstances and violating principles of natural justice. Order u/s 73 set aside, matter remanded for fresh consideration upon petitioner paying Rs. 1,40,00,000/- within four weeks. Petition disposed.
Multiple show cause notices issued with overlapping discrepancies, resulting in confusion and lack of opportunity for petitioner to respond adequately. Impugned order passed without considering circumstances and violating principles of natural justice. Order u/s 73 set aside, matter remanded for fresh consideration upon petitioner paying Rs. 1,40,00,000/- within four weeks. Petition disposed.
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