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 regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections were not adjudicated as Transfer Pricing Officer determined arm's length price adjustment as nil for the relevant year. Assessee's contention that E4e Healthcare is functionally dissimilar and cannot be included as a comparable was not considered by any authority. Orders passed by authorities were based on incorrect assumptions.
Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections were not adjudicated as Transfer Pricing Officer determined arm's length price adjustment as nil for the relevant year. Assessee's contention that E4e Healthcare is functionally dissimilar and cannot be included as a comparable was not considered by any authority. Orders passed by authorities were based on incorrect assumptions.
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