Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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In a writ challenging actions under PMLA, the petitioner sought to amend the main prayer to add a declaration that Sections 50 and 63 are unconstitutional. The court held that the vires of these provisions already stands upheld by the SC, and the petitioner's plea that the SC ruling is per incuriam could not be entertained in this proceeding; further, since writ proceedings are not governed by CPC procedure, the court declined to permit an amendment introducing a relief it could not consider. Accordingly, the proposed additional relief was rejected, while all other amendments were allowed - HC
In a writ challenging actions under PMLA, the petitioner sought to amend the main prayer to add a declaration that Sections 50 and 63 are unconstitutional. The court held that the vires of these provisions already stands upheld by the SC, and the petitioner's plea that the SC ruling is per incuriam could not be entertained in this proceeding; further, since writ proceedings are not governed by CPC procedure, the court declined to permit an amendment introducing a relief it could not consider. Accordingly, the proposed additional relief was rejected, while all other amendments were allowed - HC
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