Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Interim relief seeking return of re quantified proceeds was refused because an interlocutory order cannot grant final relief and releasing the funds would risk dissipation that could render the respondent's cross appeal infructuous; the reduced quantification did not map to identifiable discrete assets, creating prima facie irreparable prejudice, so the interim application was dismissed while preserving substantive rights in the main appeal. To avoid multiplicity and balance equities, all appeals arising from the adjudicatory order are to be consolidated and heard expeditiously with prescribed pleading timelines and case management steps.
Interim relief seeking return of re quantified proceeds was refused because an interlocutory order cannot grant final relief and releasing the funds would risk dissipation that could render the respondent's cross appeal infructuous; the reduced quantification did not map to identifiable discrete assets, creating prima facie irreparable prejudice, so the interim application was dismissed while preserving substantive rights in the main appeal. To avoid multiplicity and balance equities, all appeals arising from the adjudicatory order are to be consolidated and heard expeditiously with prescribed pleading timelines and case management steps.
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