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...
Transfer pricing adjustment to international transactions - Non-satisfaction of conditions prescribed u/r 10B(4) for using multiple year data. Assessee required to perform Functional Asset and Risk (FAR) analysis for each year as factors of comparability may differ. Previous years' data cannot be extrapolated without establishing identical comparability factors. TP study report relying on previous two years' data without current year data rightly rejected. Comparables selection in manufacturing segment - Rejection of certain comparables upheld due to differences in product, raw material, related party transactions exceeding 25%, and impact of intangibles on margins. Remitted to TPO to examine export filter objection for one comparable. TP adjustment in ITES segment - Transactions not covered under MAP resolution substantial. Remitted to TPO/AO for FAR analysis of non-UK transactions to determine if pricing factors similar to UK transactions for adopting MAP price. Expenditure on jigs and fixtures treated as capital expenditure, not revenue, as providing long-term enduring benefit. Assessee's policy of writing off over two years upheld. Working capital adjustment - Remitted to TPO to verify and allow similar adjustment as previous years, if granted earlier.
Transfer pricing adjustment to international transactions - Non-satisfaction of conditions prescribed u/r 10B(4) for using multiple year data. Assessee required to perform Functional Asset and Risk (FAR) analysis for each year as factors of comparability may differ. Previous years' data cannot be extrapolated without establishing identical comparability factors. TP study report relying on previous two years' data without current year data rightly rejected. Comparables selection in manufacturing segment - Rejection of certain comparables upheld due to differences in product, raw material, related party transactions exceeding 25%, and impact of intangibles on margins. Remitted to TPO to examine export filter objection for one comparable. TP adjustment in ITES segment - Transactions not covered under MAP resolution substantial. Remitted to TPO/AO for FAR analysis of non-UK transactions to determine if pricing factors similar to UK transactions for adopting MAP price. Expenditure on jigs and fixtures treated as capital expenditure, not revenue, as providing long-term enduring benefit. Assessee's policy of writing off over two years upheld. Working capital adjustment - Remitted to TPO to verify and allow similar adjustment as previous years, if granted earlier.
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