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...
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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...
Increase in cost of materials consumed due to higher exchange rate for purchases compared to previous year. Adequate explanation provided by assessee regarding increase in ratio of material cost to revenue, overall profitability improvement, and forex rate change details. Ad-hoc addition without examining assessee's submissions cannot be made. Commission expenses increased, assessee provided reasons. Ad-hoc disallowance without finding defects in submissions impermissible. Disallowance u/s 40(a)(ia) incorrect as commission paid to residents, not non-residents. Assessee offered 30% disallowance for non-deduction in return. CIT(A)'s order deleting additions upheld by ITAT.
Increase in cost of materials consumed due to higher exchange rate for purchases compared to previous year. Adequate explanation provided by assessee regarding increase in ratio of material cost to revenue, overall profitability improvement, and forex rate change details. Ad-hoc addition without examining assessee's submissions cannot be made. Commission expenses increased, assessee provided reasons. Ad-hoc disallowance without finding defects in submissions impermissible. Disallowance u/s 40(a)(ia) incorrect as commission paid to residents, not non-residents. Assessee offered 30% disallowance for non-deduction in return. CIT(A)'s order deleting additions upheld by ITAT.
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