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 - The Appellate Tribunal considered the amendment made to the section, which specified domestic transactions exceeding a certain threshold. The Tribunal noted that the transactions in question were not international transactions and did not fall under the ambit of Section 92BA. Consequently, it deemed the upward adjustments made by the Assessing Officer invalid. - Delving into the effect of the omission of Section 92BA from the statute, the Tribunal cited legal principles indicating that when a provision is repealed, it should be considered as if it never existed. Therefore, the Tribunal reasoned that the decision made by the Assessing Officer based on Section 92BA was without jurisdiction and liable to be quashed.
TP Adjustment - The Appellate Tribunal considered the amendment made to the section, which specified domestic transactions exceeding a certain threshold. The Tribunal noted that the transactions in question were not international transactions and did not fall under the ambit of Section 92BA. Consequently, it deemed the upward adjustments made by the Assessing Officer invalid. - Delving into the effect of the omission of Section 92BA from the statute, the Tribunal cited legal principles indicating that when a provision is repealed, it should be considered as if it never existed. Therefore, the Tribunal reasoned that the decision made by the Assessing Officer based on Section 92BA was without jurisdiction and liable to be quashed.
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