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...
Income taxable u/s 28(iv) - additions as 'benefit' by waiver of loans - As per the decision of Apex Court, the purpose of loan was neither dealt with nor would be a relevant determinative factor. The only test is that the 'benefit' or 'perquisite' should be other than ‘in the shape of money’. - The amendment vide Finance Act, 2023 also substantiate the findings of the Apex Court - Additions deleted - HC
Income taxable u/s 28(iv) - additions as 'benefit' by waiver of loans - As per the decision of Apex Court, the purpose of loan was neither dealt with nor would be a relevant determinative factor. The only test is that the 'benefit' or 'perquisite' should be other than ‘in the shape of money’. - The amendment vide Finance Act, 2023 also substantiate the findings of the Apex Court - Additions deleted - HC
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