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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Levy of late filing fee u/s 234E - Decisions relied by the Ld. AR of the assessee are on the point that the TDS return processed u/s 200A prior to 01.06.2015 would not attract the provisions of section 234E of the Act as the Assessing Officer was not having any power to make such adjustment prior to the amendment w.e.f. 01.06.2015. Accordingly, we modify the impugned orders of the Assessing Officer as well as of the Ld. CIT(A) and direct the Assessing Officer to compute the late filing fee u/s 234E of the Act for a delay w.e.f. 01.06.2015 till the filing of the TDS return. - AT
Levy of late filing fee u/s 234E - Decisions relied by the Ld. AR of the assessee are on the point that the TDS return processed u/s 200A prior to 01.06.2015 would not attract the provisions of section 234E of the Act as the Assessing Officer was not having any power to make such adjustment prior to the amendment w.e.f. 01.06.2015. Accordingly, we modify the impugned orders of the Assessing Officer as well as of the Ld. CIT(A) and direct the Assessing Officer to compute the late filing fee u/s 234E of the Act for a delay w.e.f. 01.06.2015 till the filing of the TDS return. - AT
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