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...
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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 194H - disallowance u/s 40(ia) - discount to the distributors for starter packs and recharge coupons for its prepaid services - apart from CIT(A)’s order setting aside the order passed u/s 201 was not carried in appeal tribunal independently find that transaction was on principal to principal basis, TDS u/s 194H, would not be made since the payment was not for commission or brokerage - no disallowance is called for
TDS u/s 194H - disallowance u/s 40(ia) - discount to the distributors for starter packs and recharge coupons for its prepaid services - apart from CIT(A)’s order setting aside the order passed u/s 201 was not carried in appeal tribunal independently find that transaction was on principal to principal basis, TDS u/s 194H, would not be made since the payment was not for commission or brokerage - no disallowance is called for
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