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...
Deferred (contingent) consideration not accrued during relevant previous year as right to receive it was contingent upon achievement of revenue targets. Charging and computation provisions for capital gains to be read together. Accrual stage reached only when legally enforceable right to receive arises. Cost of acquisition of shares remanded for verification. Admission of additional ground regarding application of Most Favoured Nation clause for lower dividend tax rate as per India-Slovenia DTAA, remanded to AO for adjudication.
Deferred (contingent) consideration not accrued during relevant previous year as right to receive it was contingent upon achievement of revenue targets. Charging and computation provisions for capital gains to be read together. Accrual stage reached only when legally enforceable right to receive arises. Cost of acquisition of shares remanded for verification. Admission of additional ground regarding application of Most Favoured Nation clause for lower dividend tax rate as per India-Slovenia DTAA, remanded to AO for adjudication.
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