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...
Long term capital asset as per Section 2(42A) - period of holding - Memorandum explaining the provision in the Finance Bill - after taking into consideration that the condition for the period of holding was curtailed from 36 months to 12 months by the Finance Act, 1987, it was only for 'share held in a company' - the said Memorandum clearly makes a distinction between the company shares and other than company shares. The above decision of the ITAT has laid down the correct legal principle which we have discussed in the preceding paragraphs. - HC
Long term capital asset as per Section 2(42A) - period of holding - Memorandum explaining the provision in the Finance Bill - after taking into consideration that the condition for the period of holding was curtailed from 36 months to 12 months by the Finance Act, 1987, it was only for 'share held in a company' - the said Memorandum clearly makes a distinction between the company shares and other than company shares. The above decision of the ITAT has laid down the correct legal principle which we have discussed in the preceding paragraphs. - HC
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