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...
TP Adjustment - comparable selection - The Tribunal upheld the inclusion of HSIL Limited in the list of comparables, considering its core business activities in manufacturing and selling sanitaryware products. Despite some functional diversity, the Tribunal found the core activities sufficiently similar for comparison purposes. - The Tribunal directed the exclusion of Cera Sanitaryware Limited from the list of comparables. It noted that while the functions performed by Cera Sanitaryware Limited were similar to the Assessee's, the lack of proportionate revenue data for different activities made it unreliable for benchmarking purposes.
TP Adjustment - comparable selection - The Tribunal upheld the inclusion of HSIL Limited in the list of comparables, considering its core business activities in manufacturing and selling sanitaryware products. Despite some functional diversity, the Tribunal found the core activities sufficiently similar for comparison purposes. - The Tribunal directed the exclusion of Cera Sanitaryware Limited from the list of comparables. It noted that while the functions performed by Cera Sanitaryware Limited were similar to the Assessee's, the lack of proportionate revenue data for different activities made it unreliable for benchmarking purposes.
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