Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Transfer pricing disputes resolved under the India-Japan MAP can be given effect only after the assessee withdraws the appeal ground covered by the resolution. Article 25 of the treaty was invoked for the transaction with Japanese associated enterprises, and the assessee stated that it would accept the competent authorities' resolution. Under Rule 44G, the Assessing Officer is to pass orders giving effect to the MAP resolution once the related appeal is withdrawn. The assessee accordingly requested withdrawal of the relevant ground, and the tax department raised no objection.
Transfer pricing disputes resolved under the India-Japan MAP can be given effect only after the assessee withdraws the appeal ground covered by the resolution. Article 25 of the treaty was invoked for the transaction with Japanese associated enterprises, and the assessee stated that it would accept the competent authorities' resolution. Under Rule 44G, the Assessing Officer is to pass orders giving effect to the MAP resolution once the related appeal is withdrawn. The assessee accordingly requested withdrawal of the relevant ground, and the tax department raised no objection.
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