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 - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the assessee (i.e. step down subsidiary of the associated enterprise) - The tribunal upheld the transfer pricing adjustments made by the tax authorities, distinguishing the nature of the transaction as an international transaction subject to transfer pricing provisions, despite the merger's approval by regulatory bodies. - The ruling emphasized that transactions, even if approved by regulatory bodies, must still be assessed for arm's length compliance within the framework of transfer pricing laws.
TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the assessee (i.e. step down subsidiary of the associated enterprise) - The tribunal upheld the transfer pricing adjustments made by the tax authorities, distinguishing the nature of the transaction as an international transaction subject to transfer pricing provisions, despite the merger's approval by regulatory bodies. - The ruling emphasized that transactions, even if approved by regulatory bodies, must still be assessed for arm's length compliance within the framework of transfer pricing laws.
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