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...
Blocking of the electronic credit ledger was challenged while parallel proceedings imposing tax, interest, fee and penalty under statutory tax provisions were pending; the petitioner's failure to disclose those proceedings in the writ was held material and counselling non-interference by the writ forum. Because the re-blocking related to an assessment and penalty demand of substantial amount and the statutory one year period since initial blocking had not expired, the court declined to interfere and dismissed the writ, leaving the statutory adjudication and credit availability/utilisation to proceed.
Blocking of the electronic credit ledger was challenged while parallel proceedings imposing tax, interest, fee and penalty under statutory tax provisions were pending; the petitioner's failure to disclose those proceedings in the writ was held material and counselling non-interference by the writ forum. Because the re-blocking related to an assessment and penalty demand of substantial amount and the statutory one year period since initial blocking had not expired, the court declined to interfere and dismissed the writ, leaving the statutory adjudication and credit availability/utilisation to proceed.
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TaxTMI 
TaxTMI 
of 4881 
