Withdrawal of obsolete FEMA circulars streamlines rules on external commercial borrowings, non-resident bond investments, and money transfer sub-agent...
Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
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Rule 29 compliance for additional evidence required fresh examination where an affidavit accompanying Paper Book No. II-A expressly sought permission and the materials were prima facie available in the Tribunal's records. The dismissal of the related rectification application was partly set aside and remitted for determining whether the paper book had been properly filed under Rule 29, whether its contents were relevant to the appeal, and any consequential relief. Findings concerning the other paper book and remaining grounds remained undisturbed.
Rule 29 compliance for additional evidence required fresh examination where an affidavit accompanying Paper Book No. II-A expressly sought permission and the materials were prima facie available in the Tribunal's records. The dismissal of the related rectification application was partly set aside and remitted for determining whether the paper book had been properly filed under Rule 29, whether its contents were relevant to the appeal, and any consequential relief. Findings concerning the other paper book and remaining grounds remained undisturbed.
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