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...
Import of Business Support Services - Import from Branch office situated outside India - Reverse Charge (RCM) - a comprehensive reading of Section 66A of the Act, would indicate that a permanent establishment situated abroad as a ‘separate person’, is only to determine whether the provision of service is in India or out of India. - The charging section is section 66 of the Act and not section 66A - Demand set aside - AT
Import of Business Support Services - Import from Branch office situated outside India - Reverse Charge (RCM) - a comprehensive reading of Section 66A of the Act, would indicate that a permanent establishment situated abroad as a ‘separate person’, is only to determine whether the provision of service is in India or out of India. - The charging section is section 66 of the Act and not section 66A - Demand set aside - AT
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