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...
The Appellate Tribunal addressed various issues in the case. Firstly, regarding disallowance u/s. 14A r.w.r. 8D, the Tribunal upheld the consistency principle in the methodology of computation accepted in prior years. Secondly, it ruled in favor of the assessee on the nature of expenses, considering expenditure on shelved projects as revenue. Thirdly, it allowed prior period expenditure disallowance based on mercantile accounting. Fourthly, it reversed the disallowance of discount on Euro Notes issuance. Fifthly, it directed the AO to decide on premium deduction impact u/s. 80IA based on previous rulings. Sixthly, it upheld the deduction claim u/s. 80IA for a wind power project. Seventhly, it remanded the issue of duplicate disallowance for re-examination. Lastly, it addressed Transfer Pricing adjustments, including guarantee fees and loan interest, directing the TPO to reconsider certain aspects for TP adjustments.
The Appellate Tribunal addressed various issues in the case. Firstly, regarding disallowance u/s. 14A r.w.r. 8D, the Tribunal upheld the consistency principle in the methodology of computation accepted in prior years. Secondly, it ruled in favor of the assessee on the nature of expenses, considering expenditure on shelved projects as revenue. Thirdly, it allowed prior period expenditure disallowance based on mercantile accounting. Fourthly, it reversed the disallowance of discount on Euro Notes issuance. Fifthly, it directed the AO to decide on premium deduction impact u/s. 80IA based on previous rulings. Sixthly, it upheld the deduction claim u/s. 80IA for a wind power project. Seventhly, it remanded the issue of duplicate disallowance for re-examination. Lastly, it addressed Transfer Pricing adjustments, including guarantee fees and loan interest, directing the TPO to reconsider certain aspects for TP adjustments.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
