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...
Petitioner failed to establish non-payment of tax demanded was beyond their control. CC reasonably exercised powers u/s 220(2A) after considering relevant circumstances and material on record. Factual findings supported by evidence, no perversity. Chander Prakash Jain case distinguishable on facts, not involving Section 220(2A). HC does not exercise appellate jurisdiction. All three preconditions for waiver u/s 220(2A) not met. Petition dismissed.
Petitioner failed to establish non-payment of tax demanded was beyond their control. CC reasonably exercised powers u/s 220(2A) after considering relevant circumstances and material on record. Factual findings supported by evidence, no perversity. Chander Prakash Jain case distinguishable on facts, not involving Section 220(2A). HC does not exercise appellate jurisdiction. All three preconditions for waiver u/s 220(2A) not met. Petition dismissed.
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