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...
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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