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...
Income accrued in India or not - Dependent Agent - PE in India or not? - The Tribunal upheld the assessee's argument that its operations did not constitute a business connection or PE in India, as core activities were conducted outside the country. Previous Tribunal decisions supported the conclusion that the Indian branch's activities were preparatory/auxiliary and did not constitute a PE. The Tribunal directed the assessing officer to allow TDS credit as claimed and dismissed penalty proceedings and interest levy.
Income accrued in India or not - Dependent Agent - PE in India or not? - The Tribunal upheld the assessee's argument that its operations did not constitute a business connection or PE in India, as core activities were conducted outside the country. Previous Tribunal decisions supported the conclusion that the Indian branch's activities were preparatory/auxiliary and did not constitute a PE. The Tribunal directed the assessing officer to allow TDS credit as claimed and dismissed penalty proceedings and interest levy.
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