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...
Transfer Pricing Adjustment on Delayed Receipt of Export Proceeds - notional interest - The Appellate Tribunal found that the CIT(A) had dismissed the new contention of treating receivables from AEs and non-AEs equally without proper examination, relying on a judgment that didn't restrict the assessee from raising new arguments. Noting that the previous judgment cited by the CIT(A) was not applicable in the current case, the Tribunal deemed the dismissal unjustified. Consequently, the matter was remanded back to the CIT(A) for a fresh examination, allowing the assessee to present all relevant contentions and evidence.
Transfer Pricing Adjustment on Delayed Receipt of Export Proceeds - notional interest - The Appellate Tribunal found that the CIT(A) had dismissed the new contention of treating receivables from AEs and non-AEs equally without proper examination, relying on a judgment that didn't restrict the assessee from raising new arguments. Noting that the previous judgment cited by the CIT(A) was not applicable in the current case, the Tribunal deemed the dismissal unjustified. Consequently, the matter was remanded back to the CIT(A) for a fresh examination, allowing the assessee to present all relevant contentions and evidence.
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