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...
Inordinate delay in adjudication of show cause notice by revenue authorities constitutes breach of fair procedure and violates principles of natural justice, causing prejudice to petitioners. Adjudicating authorities are obligated to adjudicate within reasonable time, failure of which warrants quashing of delayed adjudications lacking compelling justification. Unreasonable delay renders it impossible for petitioners to plan business or account for contingent liabilities, thereby breaching procedural fairness mandated in fiscal matters. Precedents establish that such egregious delays without cogent explanations necessitate quashing of impugned adjudications by High Court to uphold principles of natural justice.
Inordinate delay in adjudication of show cause notice by revenue authorities constitutes breach of fair procedure and violates principles of natural justice, causing prejudice to petitioners. Adjudicating authorities are obligated to adjudicate within reasonable time, failure of which warrants quashing of delayed adjudications lacking compelling justification. Unreasonable delay renders it impossible for petitioners to plan business or account for contingent liabilities, thereby breaching procedural fairness mandated in fiscal matters. Precedents establish that such egregious delays without cogent explanations necessitate quashing of impugned adjudications by High Court to uphold principles of natural justice.
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TaxTMI 
TaxTMI 
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