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...
Validity of order passed by jurisdictional AO not in compliance with section 144B discussed; technical glitches faced by revenue leading to transfer by PCIT to jurisdictional AO not reflected on ITBA portal; circular dated 06.09.2021 and letter dated 01.08.2023 clarified order transfer with CBDT approval. TP adjustment - comparable selection - deselection of comparables for turnover exceeding 200 crores against assessee's 14.53 crores in ITeS segment. Deselection of Manipal Digital Systems Pvt. Ltd. for lacking segmental service details. Working capital adjustment allowed following Coordinate Bench decision in Huawei Technologies India case. Non-granting of set-off of brought forward losses against final adjustment erroneous; AO directed to grant set-off. ITAT = Appellate Tribunal.
Validity of order passed by jurisdictional AO not in compliance with section 144B discussed; technical glitches faced by revenue leading to transfer by PCIT to jurisdictional AO not reflected on ITBA portal; circular dated 06.09.2021 and letter dated 01.08.2023 clarified order transfer with CBDT approval. TP adjustment - comparable selection - deselection of comparables for turnover exceeding 200 crores against assessee's 14.53 crores in ITeS segment. Deselection of Manipal Digital Systems Pvt. Ltd. for lacking segmental service details. Working capital adjustment allowed following Coordinate Bench decision in Huawei Technologies India case. Non-granting of set-off of brought forward losses against final adjustment erroneous; AO directed to grant set-off. ITAT = Appellate Tribunal.
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