Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
The clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law.
The clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law.
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