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...
TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned dispute resolution panel with respect to granting of working capital adjustment. Even in the transfer pricing study report it could not be shown that assessee himself has claimed any working capital adjustment while preparing its comparability analysis - Additions confirmed - AT
TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned dispute resolution panel with respect to granting of working capital adjustment. Even in the transfer pricing study report it could not be shown that assessee himself has claimed any working capital adjustment while preparing its comparability analysis - Additions confirmed - AT
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