Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
Management support services supported by agreements, invoices, allocation records, presentations, e-mails and time sheets were treated as genuine business services, not mere stewardship or shareholder activities, so the arm's length price could not be fixed at nil without applying a recognised transfer pricing method. In the manufacturing segment, TNMM analysis showed the tested party's operating margin remained higher than the corrected comparable margin, so no transfer pricing adjustment could survive. The appellate deletion of both adjustments was sustained.
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