International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Time limitation for passing an order u/s 92CA is a contentious issue. The Tribunal followed the Madras High Court's decision in Pfizer Healthcare, but the Revenue has filed an SLP challenging it before the Supreme Court. Interpretation of Section 92CA's interplay with Section 153 regarding limitation is pending consideration by the Supreme Court. The Bombay High Court's order in PayPal Payments is also challenged before the Supreme Court. To avoid multiplicity of proceedings, the appeals are adjourned sine die, awaiting the Supreme Court's rulings on these issues. Proceeding otherwise would necessitate cross-appeals, adding to the multiplicity.
Time limitation for passing an order u/s 92CA is a contentious issue. The Tribunal followed the Madras High Court's decision in Pfizer Healthcare, but the Revenue has filed an SLP challenging it before the Supreme Court. Interpretation of Section 92CA's interplay with Section 153 regarding limitation is pending consideration by the Supreme Court. The Bombay High Court's order in PayPal Payments is also challenged before the Supreme Court. To avoid multiplicity of proceedings, the appeals are adjourned sine die, awaiting the Supreme Court's rulings on these issues. Proceeding otherwise would necessitate cross-appeals, adding to the multiplicity.
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