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 Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the purchase of development rights, including the applicability of transfer pricing provisions to transactions capitalized in the books of accounts and not directly affecting the profit and loss account. One of the most contentious issues was the use of circle rates for determining the arm's length price of the transaction. Circle rates, usually used for stamp duty purposes, were considered by the TPO as a benchmark for the arm's length price. - The tribunal concludes that the omission of clause (i) of section 92BA of the Income Tax Act, 1961, should be treated as if the clause had never been part of the statute, thereby precluding transfer pricing adjustments on specified domestic transactions from the date of omission.
Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the purchase of development rights, including the applicability of transfer pricing provisions to transactions capitalized in the books of accounts and not directly affecting the profit and loss account. One of the most contentious issues was the use of circle rates for determining the arm's length price of the transaction. Circle rates, usually used for stamp duty purposes, were considered by the TPO as a benchmark for the arm's length price. - The tribunal concludes that the omission of clause (i) of section 92BA of the Income Tax Act, 1961, should be treated as if the clause had never been part of the statute, thereby precluding transfer pricing adjustments on specified domestic transactions from the date of omission.
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