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 appellant relied on the Delhi High Court's judgment in Kusum Health Care Pvt. Ltd., which held that once working capital adjustment is granted, there is no need to impute interest on outstanding receivables at year-end as it gets subsumed in the working capital adjustment. The Tribunal agreed with this proposition but directed the TPO to examine the bills and ascertain whether interest should be imputed on bills realized after the credit period of 70 days. The High Court modified the order, directing the TPO to look into the entire aspect in light of the Kusum Health Care judgment and pass orders accordingly, without imputing interest on the bills.
The appellant relied on the Delhi High Court's judgment in Kusum Health Care Pvt. Ltd., which held that once working capital adjustment is granted, there is no need to impute interest on outstanding receivables at year-end as it gets subsumed in the working capital adjustment. The Tribunal agreed with this proposition but directed the TPO to examine the bills and ascertain whether interest should be imputed on bills realized after the credit period of 70 days. The High Court modified the order, directing the TPO to look into the entire aspect in light of the Kusum Health Care judgment and pass orders accordingly, without imputing interest on the bills.
Note: It is a system-generated summary and is for quick reference only.