https://www.taxtmi.com/caselaws?id=759326 A writ challenge to an order under Section 201(1) and Section 201(1A) of the Income-tax Act was declined because an efficacious statutory appeal under Section 253 was available. The Bombay HC treated the controversy as involving mixed questions of fact and law on the taxability of consideration for trademark-related intellectual property, the applicability of Section 195, and the territoriality principle. It noted no patent lack of jurisdiction or gross illegality to justify bypassing the appellate remedy, and the factual examination of the agreement and surrounding circumstances was better suited to appeal. The limitation issue under Section 201 was also regarded as suitable for appellate consideration. en-us Mon, 23 Sep 2024 00:00:00 +0530 Fri, 27 Sep 2024 10:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759326 A writ challenge to an order under Section 201(1) and Section 201(1A) of the Income-tax Act was declined because an efficacious statutory appeal under Section 253 was available. The Bombay HC treated the controversy as involving mixed questions of fact and law on the taxability of consideration for trademark-related intellectual property, the applicability of Section 195, and the territoriality principle. It noted no patent lack of jurisdiction or gross illegality to justify bypassing the appellate remedy, and the factual examination of the agreement and surrounding circumstances was better suited to appeal. The limitation issue under Section 201 was also regarded as suitable for appellate consideration. Case-Laws Income Tax Mon, 23 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759326