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...
TDS u/s 194H or 192 - addition u/s 40(a)(ia) - Non-deduction of TDS on payment of commission to directors - appellant considered payment as salary and deducted TDS u/s 192 - Held: Issue covered by assessee's own case wherein commission paid to CMD shown as part of salary in Form-16 for AY 2010-11 - Section 192 requires TDS deduction under head "Salary" only at time of payment - Quantum of accrual of expenses not disputed - No infirmity in CIT(A)'s order deleting addition made by AO u/s 40(a)(ia) - Decided against revenue.
TDS u/s 194H or 192 - addition u/s 40(a)(ia) - Non-deduction of TDS on payment of commission to directors - appellant considered payment as salary and deducted TDS u/s 192 - Held: Issue covered by assessee's own case wherein commission paid to CMD shown as part of salary in Form-16 for AY 2010-11 - Section 192 requires TDS deduction under head "Salary" only at time of payment - Quantum of accrual of expenses not disputed - No infirmity in CIT(A)'s order deleting addition made by AO u/s 40(a)(ia) - Decided against revenue.
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