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...
TNMM aggregation prevented separate benchmarking of IT support services where accepted segmental margins already included the associated-enterprise markup and the services were inextricably linked to the core business. The transfer-pricing adjustment on the IT support-services margin was deleted. Notional interest on overdue associated-enterprise receivables was unwarranted because the taxpayer was debt-free, incurred no significant interest cost, and no new material justified departure from earlier treatment; the related adjustment was deleted. Capital expenditure on an in-house scientific-research facility remained deductible under section 35(1)(iv) despite the concessional tax regime and absence of valid Form 3CM, which was relevant to section 35(2AB), not section 35(1)(iv).
TNMM aggregation prevented separate benchmarking of IT support services where accepted segmental margins already included the associated-enterprise markup and the services were inextricably linked to the core business. The transfer-pricing adjustment on the IT support-services margin was deleted. Notional interest on overdue associated-enterprise receivables was unwarranted because the taxpayer was debt-free, incurred no significant interest cost, and no new material justified departure from earlier treatment; the related adjustment was deleted. Capital expenditure on an in-house scientific-research facility remained deductible under section 35(1)(iv) despite the concessional tax regime and absence of valid Form 3CM, which was relevant to section 35(2AB), not section 35(1)(iv).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
