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...
Various disallowances and additions made by the Assessing Officer (AO) and the Income Tax Appellate Tribunal's (ITAT) decisions on the same. The key points are: 1) Disallowance u/s 40(a)(ia) for non-deduction of TDS on ocean freight charges was deleted, as per CBDT circular, neither Section 194C nor 195 is applicable to such payments. 2) Disallowance of entire traveling expenses was restricted to 25% as no proof of business purpose was provided. 3) Addition u/s 41(1) for outstanding sundry creditors was deleted as the amount was offered to tax in the subsequent year, avoiding double taxation. 4) Disallowance of motor car expenses and depreciation was restricted to 10% for personal use, following judicial precedents. 5) Disallowance of excess interest payment u/s 40A(2)(b) was deleted, relying on the Gujarat High Court decision.
Various disallowances and additions made by the Assessing Officer (AO) and the Income Tax Appellate Tribunal's (ITAT) decisions on the same. The key points are: 1) Disallowance u/s 40(a)(ia) for non-deduction of TDS on ocean freight charges was deleted, as per CBDT circular, neither Section 194C nor 195 is applicable to such payments. 2) Disallowance of entire traveling expenses was restricted to 25% as no proof of business purpose was provided. 3) Addition u/s 41(1) for outstanding sundry creditors was deleted as the amount was offered to tax in the subsequent year, avoiding double taxation. 4) Disallowance of motor car expenses and depreciation was restricted to 10% for personal use, following judicial precedents. 5) Disallowance of excess interest payment u/s 40A(2)(b) was deleted, relying on the Gujarat High Court decision.
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