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...
TP Adjustment - Comparable selection - In view of the fact that the AR has simply harped on the high profit margin as a reason for seeking exclusion without pointing out any abnormal business conditions existing with that company for the year under consideration, we find no reason to disturb the conclusion drawn by the CIT(A) in echoing the inclusion of ICC International Agencies Ltd. (Segment) in the list of comparables. - AT
TP Adjustment - Comparable selection - In view of the fact that the AR has simply harped on the high profit margin as a reason for seeking exclusion without pointing out any abnormal business conditions existing with that company for the year under consideration, we find no reason to disturb the conclusion drawn by the CIT(A) in echoing the inclusion of ICC International Agencies Ltd. (Segment) in the list of comparables. - AT
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