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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TP Adjustment - selection of MAM [Most Appropriate Method] - The High Court upheld the Tribunal's decision, affirming TNMM as the appropriate method for benchmarking transactions. It criticized the TPO's one-to-one comparison and affirmed Assessee's use of TNMM. The High Court found fault with the TPO's reliance on the Bloomberg database without adequate clarification or consideration of Assessee's objections. It supported Assessee's contention regarding the reliability of Indian Customs data.
TP Adjustment - selection of MAM [Most Appropriate Method] - The High Court upheld the Tribunal's decision, affirming TNMM as the appropriate method for benchmarking transactions. It criticized the TPO's one-to-one comparison and affirmed Assessee's use of TNMM. The High Court found fault with the TPO's reliance on the Bloomberg database without adequate clarification or consideration of Assessee's objections. It supported Assessee's contention regarding the reliability of Indian Customs data.
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