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...
Amount outstanding from the trade debtors - non-charging of interest on the debtors - Assessee had not received any interest then we fail to understand as to how the Income tax authorities can fix a notional interest as due, or collected by the assessee. Our attention has not been invited to any of the provisions of the Act empowering the Income tax authorities to include in the income, interest which has not been due or collected/received at any stage by the assessee. - AT
Amount outstanding from the trade debtors - non-charging of interest on the debtors - Assessee had not received any interest then we fail to understand as to how the Income tax authorities can fix a notional interest as due, or collected by the assessee. Our attention has not been invited to any of the provisions of the Act empowering the Income tax authorities to include in the income, interest which has not been due or collected/received at any stage by the assessee. - AT
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