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...
Royalty expenditure - Capital OR Revenue - assessee purchased distribution rights of the Punjabi film - As the AO has ignored the Board Circular No. 92 dated 18.9.1972 pertaining to writing off royalty/distribution expenses of films which is binding on tax authorities thus the action of the AO was based on surmises and conjectures, without considering the nature of business of the assessee which was supported by hyper approach ignoring the Board Circular - AT
Royalty expenditure - Capital OR Revenue - assessee purchased distribution rights of the Punjabi film - As the AO has ignored the Board Circular No. 92 dated 18.9.1972 pertaining to writing off royalty/distribution expenses of films which is binding on tax authorities thus the action of the AO was based on surmises and conjectures, without considering the nature of business of the assessee which was supported by hyper approach ignoring the Board Circular - AT
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