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...
Assessment proceedings conducted by non-jurisdictional officer - Assessee participated without challenging jurisdiction - Assessment order valid as per Supreme Court ruling in DCIT vs. Kalinga Institute case. Bogus expenses - Assessee provided incomplete addresses, similar PAN numbers for different vendors - Disallowance of Rs. 20 lakhs justified considering totality of facts, assessee's inability to substantiate expenses despite reasonable profit rate declared. Estimation of 25% profit by authorities not warranted.
Assessment proceedings conducted by non-jurisdictional officer - Assessee participated without challenging jurisdiction - Assessment order valid as per Supreme Court ruling in DCIT vs. Kalinga Institute case. Bogus expenses - Assessee provided incomplete addresses, similar PAN numbers for different vendors - Disallowance of Rs. 20 lakhs justified considering totality of facts, assessee's inability to substantiate expenses despite reasonable profit rate declared. Estimation of 25% profit by authorities not warranted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
