Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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An unregistered assignment deed was treated as sufficient prima facie basis for substitution of the assignee in proceedings, because permitting the assignee to contest the matter was considered a collateral purpose distinct from determining the deed's validity or transfer effect. Relying on the principle that an unregistered document may be read for a collateral purpose, the Tribunal left all objections under Sections 17 and 49 of the Registration Act open for decision in the main company petition. The substitution of the assignee was therefore maintained, while the challenge to the assignment deed's admissibility, enforceability and legal effect was reserved for final adjudication.
An unregistered assignment deed was treated as sufficient prima facie basis for substitution of the assignee in proceedings, because permitting the assignee to contest the matter was considered a collateral purpose distinct from determining the deed's validity or transfer effect. Relying on the principle that an unregistered document may be read for a collateral purpose, the Tribunal left all objections under Sections 17 and 49 of the Registration Act open for decision in the main company petition. The substitution of the assignee was therefore maintained, while the challenge to the assignment deed's admissibility, enforceability and legal effect was reserved for final adjudication.
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