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...
TDS u/s 195 - referral fee paid to a foreign concern, in USA for introducing clients - not in the nature of Managerial services,Technical services or Consultancy fees - payment entirely constituted its business profits in USA within the meaning of Article 7 of the India-USA DTAA and in the absence of any PE the said amount could not be brought to tax in India - No obligation to deduct TDS - no disallowance
TDS u/s 195 - referral fee paid to a foreign concern, in USA for introducing clients - not in the nature of Managerial services,Technical services or Consultancy fees - payment entirely constituted its business profits in USA within the meaning of Article 7 of the India-USA DTAA and in the absence of any PE the said amount could not be brought to tax in India - No obligation to deduct TDS - no disallowance
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