Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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The dominant issue was whether a stay application under s. 220(6) could be rejected on the premise that it was not entertainable without a 20% pre-deposit of the outstanding demand. The court held that the assessing authority must exercise discretion under s. 220(6) on settled principles, including assessment of "undue hardship," and cannot treat a 20% deposit as a mandatory precondition for considering stay. Since the authority proceeded on an erroneous assumption of lack of power absent pre-deposit, the impugned rejection was set aside and the matter remitted for fresh consideration in accordance with the governing jurisprudence. - HC
The dominant issue was whether a stay application under s. 220(6) could be rejected on the premise that it was not entertainable without a 20% pre-deposit of the outstanding demand. The court held that the assessing authority must exercise discretion under s. 220(6) on settled principles, including assessment of "undue hardship," and cannot treat a 20% deposit as a mandatory precondition for considering stay. Since the authority proceeded on an erroneous assumption of lack of power absent pre-deposit, the impugned rejection was set aside and the matter remitted for fresh consideration in accordance with the governing jurisprudence. - HC
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