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...
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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 u/s 195 - disallowance u/s 40(a)(i) - The Tribunal cited precedents and legal provisions to establish that disallowance under Section 40(a)(i) can only be made when tax is deductible at source under Chapter XVII-B and has not been deducted or paid within the specified time. Considering that TDS had been deducted under Section 192 and deposited within the prescribed time, the Tribunal found no justification for disallowing expenses under Section 40(a)(i). - The Tribunal also referred to the decision in M/s Serco India Pvt. Ltd., where it was held that once tax is deducted under Section 192 for salary payments, Section 195 has no application.
TDS u/s 195 - disallowance u/s 40(a)(i) - The Tribunal cited precedents and legal provisions to establish that disallowance under Section 40(a)(i) can only be made when tax is deductible at source under Chapter XVII-B and has not been deducted or paid within the specified time. Considering that TDS had been deducted under Section 192 and deposited within the prescribed time, the Tribunal found no justification for disallowing expenses under Section 40(a)(i). - The Tribunal also referred to the decision in M/s Serco India Pvt. Ltd., where it was held that once tax is deducted under Section 192 for salary payments, Section 195 has no application.
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