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 195 - default u/s 201(1)/201(1A) - assessee deducted TDS at 10% plus surcharge on consideration paid for purchase of shares from non-resident sellers - TDS Officer re-characterized transaction from 'sale of shares' to 'sale of assets' - HELD: Assessee deducted TDS on payments made for share purchase and deposited it with Government - AO re-characterized nature of transaction in proceedings u/s 201 beyond jurisdiction - Undisputed facts show assessee not an 'assessee in default' - No infirmity in impugned order, upheld against revenue.
TDS u/s 195 - default u/s 201(1)/201(1A) - assessee deducted TDS at 10% plus surcharge on consideration paid for purchase of shares from non-resident sellers - TDS Officer re-characterized transaction from 'sale of shares' to 'sale of assets' - HELD: Assessee deducted TDS on payments made for share purchase and deposited it with Government - AO re-characterized nature of transaction in proceedings u/s 201 beyond jurisdiction - Undisputed facts show assessee not an 'assessee in default' - No infirmity in impugned order, upheld against revenue.
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