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...
Disallowance of business loss of discontinued business: Deduction for expenditure incurred towards professional charges, consultancy charges, ESI arrears, and bank charges was disallowed when the assessee's business was discontinued, as there was no likelihood of revival. Expenditure incurred when no business was carried on is not admissible deduction, as per the legal principle that loss or expenditure should be incurred in the course of business. Tax rates on Interest income: As per Article 11 of the DTAA between India and New Zealand, interest income earned by an assessee being a resident of New Zealand may be taxed at a maximum rate of 10%. The assessee, being a resident of New Zealand, is entitled to the benefit of lower tax rate under the DTAA, even though the income was not taxable in New Zealand due to temporary exemption.
Disallowance of business loss of discontinued business: Deduction for expenditure incurred towards professional charges, consultancy charges, ESI arrears, and bank charges was disallowed when the assessee's business was discontinued, as there was no likelihood of revival. Expenditure incurred when no business was carried on is not admissible deduction, as per the legal principle that loss or expenditure should be incurred in the course of business. Tax rates on Interest income: As per Article 11 of the DTAA between India and New Zealand, interest income earned by an assessee being a resident of New Zealand may be taxed at a maximum rate of 10%. The assessee, being a resident of New Zealand, is entitled to the benefit of lower tax rate under the DTAA, even though the income was not taxable in New Zealand due to temporary exemption.
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