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 195 - non-deduction of TDS on payment of export commission to Foreign entity in Italy - whether there is a business connection or not, must be determined based on facts and circumstances of the particular case. In our opinion there is nothing on record which indicates that SPA is carrying out its business in India owing to which any portion of its income can be attributed to its Indian operations. - AT
TDS u/s 195 - non-deduction of TDS on payment of export commission to Foreign entity in Italy - whether there is a business connection or not, must be determined based on facts and circumstances of the particular case. In our opinion there is nothing on record which indicates that SPA is carrying out its business in India owing to which any portion of its income can be attributed to its Indian operations. - AT
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