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...
TPA - Whether recasting of framework agreement in 2007 tantamount assignment of option rights held by the assessee under framework agreements of 2006 - Decided against the assessee - Decision in the matter of Vodafone India Holdings BV Vs. UOI [2012 (1) TMI 52 - SUPREME COURT OF INDIA] distinguished in view of subsequent amendment to Section 2(47) - AT
TPA - Whether recasting of framework agreement in 2007 tantamount assignment of option rights held by the assessee under framework agreements of 2006 - Decided against the assessee - Decision in the matter of Vodafone India Holdings BV Vs. UOI [2012 (1) TMI 52 - SUPREME COURT OF INDIA] distinguished in view of subsequent amendment to Section 2(47) - AT
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