Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Interlocutory relief under Rule 29 is contemplated only in a pending appeal. Where a statutory appeal remains under scrutiny and is not registered, stay or early-hearing relief cannot receive substantive consideration. Urgency may instead justify expedited scrutiny, subject to procedural compliance. Once deficiencies are cleared and the appeal is registered, the interlocutory application may be tagged to it and placed before the Bench for consideration.
Interlocutory relief under Rule 29 is contemplated only in a pending appeal. Where a statutory appeal remains under scrutiny and is not registered, stay or early-hearing relief cannot receive substantive consideration. Urgency may instead justify expedited scrutiny, subject to procedural compliance. Once deficiencies are cleared and the appeal is registered, the interlocutory application may be tagged to it and placed before the Bench for consideration.
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