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 assessee, a contractor or developer, was initially denied deduction u/s 80IA(4) by the Assessing Officer, citing the retrospective amendment introduced by the Finance Act, 2009, which required the assessee to be the owner of the property as a developer. However, the ITAT held that the assessee qualified as a developer within the meaning of Section 80-IA and was eligible for the deduction under Sub-section (4). The High Court upheld the concurrent findings of the CIT (Appeals) and the Tribunal, stating that the assessee was awarded a contract for full-fledged development of a new infrastructure facility at an airport, involving financial and entrepreneurial risk, thus qualifying as a developer eligible for the deduction.
The assessee, a contractor or developer, was initially denied deduction u/s 80IA(4) by the Assessing Officer, citing the retrospective amendment introduced by the Finance Act, 2009, which required the assessee to be the owner of the property as a developer. However, the ITAT held that the assessee qualified as a developer within the meaning of Section 80-IA and was eligible for the deduction under Sub-section (4). The High Court upheld the concurrent findings of the CIT (Appeals) and the Tribunal, stating that the assessee was awarded a contract for full-fledged development of a new infrastructure facility at an airport, involving financial and entrepreneurial risk, thus qualifying as a developer eligible for the deduction.
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