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 adjustments for the project business segment required fresh consideration in line with the Dispute Resolution Panel's directions, without adjudication of their merits. The ITAT restored this issue to the Transfer Pricing Officer for a lawful fresh determination after hearing the assessee. The arm's length price of intra-group services was also remanded because the Transfer Pricing Officer had accepted that price in a subsequent assessment year; the merits were not decided. The Transfer Pricing Officer must reconsider the issue after providing an opportunity of hearing. The appeals for the relevant assessment years were allowed for statistical purposes.
Transfer-pricing adjustments for the project business segment required fresh consideration in line with the Dispute Resolution Panel's directions, without adjudication of their merits. The ITAT restored this issue to the Transfer Pricing Officer for a lawful fresh determination after hearing the assessee. The arm's length price of intra-group services was also remanded because the Transfer Pricing Officer had accepted that price in a subsequent assessment year; the merits were not decided. The Transfer Pricing Officer must reconsider the issue after providing an opportunity of hearing. The appeals for the relevant assessment years were allowed for statistical purposes.
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