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...
TP Adjustment - Design Engineering Services - in the TP study report assessee applied margins at the entity level - it cannot be precluded from furnishing segmental details during TP or DRP proceedings in order to benchmark the margins of its international transactions on the basis of segmental profitability of AE segment - segmental details are to be adopted and margins of segment of AE transactions are compared with margins of comparables selected
TP Adjustment - Design Engineering Services - in the TP study report assessee applied margins at the entity level - it cannot be precluded from furnishing segmental details during TP or DRP proceedings in order to benchmark the margins of its international transactions on the basis of segmental profitability of AE segment - segmental details are to be adopted and margins of segment of AE transactions are compared with margins of comparables selected
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