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...
TDS liability u/s 194C - 'Contract for Sale' and not a 'Works Contract' - Scope of the term "Work" - Seeking issue a Certificate u/s 197 r.w.s. 206(C)(9) for NIL Tax Deduction at Source (TDS) on all sales effected by the Petitioner/ Company - The burden of proof regarding the nature of transactions between the assessee and Hindustan Lever Limited (HUL) falls on the assessee. The court emphasizes the importance of providing sufficient documentation to support the claim that the transactions do not fall under Section 194C but rather under a different category, such as a contract for sale. - Ultimately, the court disposes of the writ petitions, indicating that the petitioner's claims are not legally tenable given their past treatment of payments from HUL and the lack of documents disputing the tax deductions made by HUL.
TDS liability u/s 194C - 'Contract for Sale' and not a 'Works Contract' - Scope of the term "Work" - Seeking issue a Certificate u/s 197 r.w.s. 206(C)(9) for NIL Tax Deduction at Source (TDS) on all sales effected by the Petitioner/ Company - The burden of proof regarding the nature of transactions between the assessee and Hindustan Lever Limited (HUL) falls on the assessee. The court emphasizes the importance of providing sufficient documentation to support the claim that the transactions do not fall under Section 194C but rather under a different category, such as a contract for sale. - Ultimately, the court disposes of the writ petitions, indicating that the petitioner's claims are not legally tenable given their past treatment of payments from HUL and the lack of documents disputing the tax deductions made by HUL.
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