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...
Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for comparability - TPO rejected TNMM, applied CUP method - directed to consider both overseas and domestic clients while applying CUP method. No adjustment of marketing cost while applying CUP method, not granting adjustment of research cost and volume - directed to allow 40% adjustment on marketing and research cost. Computing upward adjustment by considering addition instead of rectified amount - issue restored to AO for giving effect as per TPO's rectification order. Disallowance of net loss incurred on error trading transactions - directed to allow as incidental to assessee's broking business. Disallowance u/s 14A - issue remanded to AO to examine disallowance and assessee to substantiate claim.
Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for comparability - TPO rejected TNMM, applied CUP method - directed to consider both overseas and domestic clients while applying CUP method. No adjustment of marketing cost while applying CUP method, not granting adjustment of research cost and volume - directed to allow 40% adjustment on marketing and research cost. Computing upward adjustment by considering addition instead of rectified amount - issue restored to AO for giving effect as per TPO's rectification order. Disallowance of net loss incurred on error trading transactions - directed to allow as incidental to assessee's broking business. Disallowance u/s 14A - issue remanded to AO to examine disallowance and assessee to substantiate claim.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
