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...
Transfer pricing of intra-group services required fresh examination because CUP could not be applied at nil without uncontrolled comparable transactions, and the TPO had to consider the evidence and additional evidence on actual receipt and nature of services; the impugned adjustment was therefore set aside and remanded. On unabsorbed depreciation, the Tribunal held that depreciation relating to earlier years, not absorbed by financial year 2002-03, merged with subsequent-year depreciation and was not subject to the earlier eight-year restriction after the amendment to section 32(2); the assessee's claim for carry forward and set-off beyond eight years was allowed and the Revenue's challenge was rejected.
Transfer pricing of intra-group services required fresh examination because CUP could not be applied at nil without uncontrolled comparable transactions, and the TPO had to consider the evidence and additional evidence on actual receipt and nature of services; the impugned adjustment was therefore set aside and remanded. On unabsorbed depreciation, the Tribunal held that depreciation relating to earlier years, not absorbed by financial year 2002-03, merged with subsequent-year depreciation and was not subject to the earlier eight-year restriction after the amendment to section 32(2); the assessee's claim for carry forward and set-off beyond eight years was allowed and the Revenue's challenge was rejected.
Note: It is a system-generated summary and is for quick reference only.