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...
Writ relief was held impermissible where an efficacious statutory appeal existed and the petitioner failed to respond to portal notices; the court found no breach of natural justice because notices and show-cause drafts were made available and no reply or request for personal hearing was filed, and substantive disputes-mismatch between TDS credit and GSTR 1/3B, clerical classification of supplies and correctness of tax liability-must be raised in appeal before the appellate authority; further, the writ cannot be used to avoid the statutory pre-deposit requirement, and the petition was dismissed.
Writ relief was held impermissible where an efficacious statutory appeal existed and the petitioner failed to respond to portal notices; the court found no breach of natural justice because notices and show-cause drafts were made available and no reply or request for personal hearing was filed, and substantive disputes-mismatch between TDS credit and GSTR 1/3B, clerical classification of supplies and correctness of tax liability-must be raised in appeal before the appellate authority; further, the writ cannot be used to avoid the statutory pre-deposit requirement, and the petition was dismissed.
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