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 - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of outstanding receivables as a separate international transaction - Common policy of not charging interest on delayed payments from AEs and third parties - Ultimately, the ITAT partly allowed the assessee's appeal, directing adjustments to be computed following the directions of the DRP. This included considering the receivables cleared within specific timeframes and applying appropriate interest rates. - The Tribunal emphasized the need for a case-by-case examination of transactions and directed the AO to set off receivables cleared within certain periods.
TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of outstanding receivables as a separate international transaction - Common policy of not charging interest on delayed payments from AEs and third parties - Ultimately, the ITAT partly allowed the assessee's appeal, directing adjustments to be computed following the directions of the DRP. This included considering the receivables cleared within specific timeframes and applying appropriate interest rates. - The Tribunal emphasized the need for a case-by-case examination of transactions and directed the AO to set off receivables cleared within certain periods.
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