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...
TDS u/s 194J - A&M expenses - Non deduction of TDS - The claims made for selling and distribution network of sub-distributors was settled by HUL and reimbursed the same by the appellant company. - the genuineness of business expenditure is beyond the doubt. - neither the impugned expenditure falls within the ambit of “managerial services” as defined in section 9(1)(vii) of the Act nor liable to deduct tax at source u/s 194J - AT
TDS u/s 194J - A&M expenses - Non deduction of TDS - The claims made for selling and distribution network of sub-distributors was settled by HUL and reimbursed the same by the appellant company. - the genuineness of business expenditure is beyond the doubt. - neither the impugned expenditure falls within the ambit of “managerial services” as defined in section 9(1)(vii) of the Act nor liable to deduct tax at source u/s 194J - AT
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