Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Rule 86A(2) empowers the Commissioner or authorised officer to permit debit of the electronic credit ledger once satisfied that the conditions justifying blockage under Rule 86A(1) no longer exist. Since the taxpayer had submitted a representation seeking unblocking and the authority had not taken any decision as mandated by Rule 86A(2), the court required administrative determination on that request. The authority was directed to pass a reasoned order on the taxpayer's representation within two weeks, and the writ petition was disposed of accordingly. - HC
Rule 86A(2) empowers the Commissioner or authorised officer to permit debit of the electronic credit ledger once satisfied that the conditions justifying blockage under Rule 86A(1) no longer exist. Since the taxpayer had submitted a representation seeking unblocking and the authority had not taken any decision as mandated by Rule 86A(2), the court required administrative determination on that request. The authority was directed to pass a reasoned order on the taxpayer's representation within two weeks, and the writ petition was disposed of accordingly. - HC
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