Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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HC granted interim stay on tax demand following appeal disposal, acknowledging non-operational status of Appellate Tribunal. Initial two-week unconditional stay granted, with extension contingent on petitioner's payment of 10% of disputed tax balance, supplementing previous Section 107(6) deposits. Stay continuation linked to either writ petition resolution or subsequent orders. Court directed filing of affidavit-in-opposition within six weeks, allowing one week for reply. Decision balanced taxpayer protection with revenue interests while addressing procedural gap due to pending Tribunal establishment.
HC granted interim stay on tax demand following appeal disposal, acknowledging non-operational status of Appellate Tribunal. Initial two-week unconditional stay granted, with extension contingent on petitioner's payment of 10% of disputed tax balance, supplementing previous Section 107(6) deposits. Stay continuation linked to either writ petition resolution or subsequent orders. Court directed filing of affidavit-in-opposition within six weeks, allowing one week for reply. Decision balanced taxpayer protection with revenue interests while addressing procedural gap due to pending Tribunal establishment.
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