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...
Receipts from standard software licences or subscriptions, together with incidental support services, were held not to constitute fees for technical services because the offerings were standardised and automated, with only a limited, non-transferable right of access or use and no transfer of source code, proprietary rights, or commercial exploitation rights. The related support was treated as ancillary to the software supply, not as separate managerial, technical, or consultancy services. On that basis, the software-related addition was deleted for A.Y. 2020-21, and the same reasoning was applied to A.Y. 2021-22. The refund adjustment issue was not decided on merits and was remanded for limited verification and consequential relief, if due.
Receipts from standard software licences or subscriptions, together with incidental support services, were held not to constitute fees for technical services because the offerings were standardised and automated, with only a limited, non-transferable right of access or use and no transfer of source code, proprietary rights, or commercial exploitation rights. The related support was treated as ancillary to the software supply, not as separate managerial, technical, or consultancy services. On that basis, the software-related addition was deleted for A.Y. 2020-21, and the same reasoning was applied to A.Y. 2021-22. The refund adjustment issue was not decided on merits and was remanded for limited verification and consequential relief, if due.
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