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...
Rectification of mistake u/s 254 - dismissal of Revenue’s appeal for low tax effect - Tribunal failed to note that para 10(c) of CBDT Circular which state that Revenue would contest appeals in respect of orders which were the result of the Department’s acceptance of Revenue audit objections, even if the tax effect in such appeal is lower than the prescribed limit - mistake apparent on record
Rectification of mistake u/s 254 - dismissal of Revenue’s appeal for low tax effect - Tribunal failed to note that para 10(c) of CBDT Circular which state that Revenue would contest appeals in respect of orders which were the result of the Department’s acceptance of Revenue audit objections, even if the tax effect in such appeal is lower than the prescribed limit - mistake apparent on record
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