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...
The liability u/s 201(1) for TDS on provisions in books of accounts was disputed by the assessee, arguing that the provisions were reversed in a subsequent year and TDS was complied with when actual invoices were booked. The appellate authority, considering the Assessee's contention and precedent of IBM India (P) Ltd., held that if TDS was deducted in a later year, demand u/s 201(1) cannot be raised, with interest u/s 201(1A) applicable only until deduction. The CIT(A) correctly granted relief on TDS payment, directing the AO to calculate interest until deduction. Revenue's appeals were dismissed by ITAT.
The liability u/s 201(1) for TDS on provisions in books of accounts was disputed by the assessee, arguing that the provisions were reversed in a subsequent year and TDS was complied with when actual invoices were booked. The appellate authority, considering the Assessee's contention and precedent of IBM India (P) Ltd., held that if TDS was deducted in a later year, demand u/s 201(1) cannot be raised, with interest u/s 201(1A) applicable only until deduction. The CIT(A) correctly granted relief on TDS payment, directing the AO to calculate interest until deduction. Revenue's appeals were dismissed by ITAT.
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