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...
Transfer Pricing Adjustments - The Tribunal upheld the Ld. DRP's directions on various objections raised by the taxpayer, including the consideration of multiple-year data, peculiar economic conditions, abnormal business loss, under-utilization of capacity, and treatment of expenses. - However, the ITAT found that the Assessing Officer (AO) had not fully complied with the Ld. DRP's directions, specifically regarding working capital adjustments. It directed the AO/TPO to consider all of the Ld. DRP's directions while drafting the final assessment order. - Matter restored back.
Transfer Pricing Adjustments - The Tribunal upheld the Ld. DRP's directions on various objections raised by the taxpayer, including the consideration of multiple-year data, peculiar economic conditions, abnormal business loss, under-utilization of capacity, and treatment of expenses. - However, the ITAT found that the Assessing Officer (AO) had not fully complied with the Ld. DRP's directions, specifically regarding working capital adjustments. It directed the AO/TPO to consider all of the Ld. DRP's directions while drafting the final assessment order. - Matter restored back.
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