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 - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment beyond the scope of the TPO's determination. It was noted that the TPO's order did not explicitly dictate the inclusion of the demerged business's value in the ALP calculation, rendering the AO's addition legally unsustainable. The judgement emphasized the sanctity of procedural adherence and the delineated roles of the AO and TPO in the context of transfer pricing adjustments. - The Court set aside the impugned order and remanded the matter back to the AO.
TP Adjustment - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment beyond the scope of the TPO's determination. It was noted that the TPO's order did not explicitly dictate the inclusion of the demerged business's value in the ALP calculation, rendering the AO's addition legally unsustainable. The judgement emphasized the sanctity of procedural adherence and the delineated roles of the AO and TPO in the context of transfer pricing adjustments. - The Court set aside the impugned order and remanded the matter back to the AO.
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