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...
Allowability of non-compete fee paid - As the case of the Assessing Officer appears to be that the non-compete consideration is nothing but a part of the consideration payable for acquisition of shares of the appellant company and, therefore, any consideration paid for acquisition of shares cannot be allowed as revenue deduction while computing the business profits as taxable. - This finding made by the Assessing Officer remains uncontroverted by leading necessary evidence on record. - the claim made by the assessee cannot be allowed as deduction - Additions confirmed - AT
Allowability of non-compete fee paid - As the case of the Assessing Officer appears to be that the non-compete consideration is nothing but a part of the consideration payable for acquisition of shares of the appellant company and, therefore, any consideration paid for acquisition of shares cannot be allowed as revenue deduction while computing the business profits as taxable. - This finding made by the Assessing Officer remains uncontroverted by leading necessary evidence on record. - the claim made by the assessee cannot be allowed as deduction - Additions confirmed - AT
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