Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
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Statutory appellate jurisdiction over refusal of court-ordered interim measures remains exclusively with the court designated under the Arbitration and Conciliation Act. An Arbitral Tribunal's power to grant interim measures cannot be converted into appellate jurisdiction over a court's interim-measure order, even with party consent. Accordingly, remitting a pending statutory appeal to a subsequently constituted Tribunal for treatment as an interim-measures application was set aside. Following the Tribunal's constitution, parties may independently seek legally available interim protection before it, while remaining disputes proceed to arbitration.
Statutory appellate jurisdiction over refusal of court-ordered interim measures remains exclusively with the court designated under the Arbitration and Conciliation Act. An Arbitral Tribunal's power to grant interim measures cannot be converted into appellate jurisdiction over a court's interim-measure order, even with party consent. Accordingly, remitting a pending statutory appeal to a subsequently constituted Tribunal for treatment as an interim-measures application was set aside. Following the Tribunal's constitution, parties may independently seek legally available interim protection before it, while remaining disputes proceed to arbitration.
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