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...
Interest income on Inter Corporate Deposits (ICD) and Fixed Deposits (FD) treated as income under "Profits & Gains of Business or Profession" instead of "Income from Other Sources" upheld. Assessee engaged in leasing and financing business as per Memorandum of Association (MOA). Non-registration as Non-Banking Finance Company (NBFC) not a valid reason for changing head of income. Rule of consistency demands consistent treatment when accepted as business income in preceding and succeeding years. Disallowance of amortized preliminary expenses set aside, directed to allow amortization consistent with treatment in other years. Appeal partly allowed.
Interest income on Inter Corporate Deposits (ICD) and Fixed Deposits (FD) treated as income under "Profits & Gains of Business or Profession" instead of "Income from Other Sources" upheld. Assessee engaged in leasing and financing business as per Memorandum of Association (MOA). Non-registration as Non-Banking Finance Company (NBFC) not a valid reason for changing head of income. Rule of consistency demands consistent treatment when accepted as business income in preceding and succeeding years. Disallowance of amortized preliminary expenses set aside, directed to allow amortization consistent with treatment in other years. Appeal partly allowed.
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