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...
Claim of expenditure against interest Income - Since, we hold in principle that the expenditure is allowable either way u/s 57, if the income is treated under the head “income from other sources” as per the provisions of Section 56 or u/s 37, if the income is treated under the head “profits and gains of business or profession” as per the provisions of Section 28, at this juncture, we refrain from determining issue of the claim of preclusion or collateral estoppel under “which head” the income earned by the assessee is taxable. - AT
Claim of expenditure against interest Income - Since, we hold in principle that the expenditure is allowable either way u/s 57, if the income is treated under the head “income from other sources” as per the provisions of Section 56 or u/s 37, if the income is treated under the head “profits and gains of business or profession” as per the provisions of Section 28, at this juncture, we refrain from determining issue of the claim of preclusion or collateral estoppel under “which head” the income earned by the assessee is taxable. - AT
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