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...
Valuation - inclusion of royalty / technical know-how to the transaction value - The tribunal noted that, the argument in regard to amendment of Rule 10 is not material to be considered for the reason that for the disputed period (2010-2013) the respondent has not paid any royalty or technical know-how fee. Therefore, the amendment has no bearing to decide the issue as to whether the transaction value accepted by the department is proper. - The CESTAT while dismissing the revenue appeal held that, there is no material pointed out to show that that the price quoted for similar goods as per NIDB data or contemporaneous imports is higher or different from the value adopted by the respondent.
Valuation - inclusion of royalty / technical know-how to the transaction value - The tribunal noted that, the argument in regard to amendment of Rule 10 is not material to be considered for the reason that for the disputed period (2010-2013) the respondent has not paid any royalty or technical know-how fee. Therefore, the amendment has no bearing to decide the issue as to whether the transaction value accepted by the department is proper. - The CESTAT while dismissing the revenue appeal held that, there is no material pointed out to show that that the price quoted for similar goods as per NIDB data or contemporaneous imports is higher or different from the value adopted by the respondent.
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