Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengeable.

Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengeable. https://www.taxtmi.com/highlights?id=104023 Questions of law proposed in an appeal from a Tribunal's miscellaneous-application order must arise from that order, rather than from an unaltered finding in the original appellate order. Where the miscellaneous order only modified the terms of remand and left intact the finding that an accepted sale-and-purchase software transaction subject to arm's length price determination did not give rise to a dependent agent permanent establishment issue, challenges to that finding fell outside the appeal's scope. The Revenue's appeal was dismissed, while its right to challenge the original Tribunal order in accordance with law remained open. en-us Tue, 22 Sep 2026 08:17:53 +0530 Tue, 22 Sep 2026 08:17:53 +0530 TaxTMI RSS Generator Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengeable. https://www.taxtmi.com/highlights?id=104023 Questions of law proposed in an appeal from a Tribunal's miscellaneous-application order must arise from that order, rather than from an unaltered finding in the original appellate order. Where the miscellaneous order only modified the terms of remand and left intact the finding that an accepted sale-and-purchase software transaction subject to arm's length price determination did not give rise to a dependent agent permanent establishment issue, challenges to that finding fell outside the appeal's scope. The Revenue's appeal was dismissed, while its right to challenge the original Tribunal order in accordance with law remained open. Highlights Income Tax Tue, 22 Sep 2026 08:17:53 +0530 https://www.taxtmi.com/highlights?id=104023