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...
Section 14A disallowance restricted to 2% of exempt income due to inapplicability of Rule 8D for the relevant assessment year. TDS disallowance u/s 40(a)(ia) upheld for payments to Team Lease for providing staff on contractual basis. Disallowance u/s 40(a)(i) for global overhead charges paid to Deutsche Securities Inc., New York deleted as payments not taxable as fees for included services under India-USA tax treaty. TPO/AO directed to recompute arm's length price after granting volume and marketing cost adjustment. Education cess disallowance upheld due to retrospective amendment. Disallowance u/s 40(a)(ia) for VSAT/lease line charges and transaction charges paid to stock exchanges deleted as not fees for technical services. Benefit of 5% variation u/s 92C(2) denied as per Special Bench ruling.
Section 14A disallowance restricted to 2% of exempt income due to inapplicability of Rule 8D for the relevant assessment year. TDS disallowance u/s 40(a)(ia) upheld for payments to Team Lease for providing staff on contractual basis. Disallowance u/s 40(a)(i) for global overhead charges paid to Deutsche Securities Inc., New York deleted as payments not taxable as fees for included services under India-USA tax treaty. TPO/AO directed to recompute arm's length price after granting volume and marketing cost adjustment. Education cess disallowance upheld due to retrospective amendment. Disallowance u/s 40(a)(ia) for VSAT/lease line charges and transaction charges paid to stock exchanges deleted as not fees for technical services. Benefit of 5% variation u/s 92C(2) denied as per Special Bench ruling.
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