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...
Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection - The Tribunal upheld that the assessee has a 'Business Connection' in India. However, it was determined that since the assessee compensated its Indian agents (ZTL and El-Zee) at an arm's length price, no further income from advertisement and subscription revenue is attributable to the assessee from operations carried out in India. - The Tribunal upheld the CIT(A)'s acceptance of the assessee's cash system of accounting, aligning with the consistency in the assessee's past accounting practices.
Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection - The Tribunal upheld that the assessee has a 'Business Connection' in India. However, it was determined that since the assessee compensated its Indian agents (ZTL and El-Zee) at an arm's length price, no further income from advertisement and subscription revenue is attributable to the assessee from operations carried out in India. - The Tribunal upheld the CIT(A)'s acceptance of the assessee's cash system of accounting, aligning with the consistency in the assessee's past accounting practices.
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