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 jurisdictional HC in the case of Schneider Electric South Asia (HQ) PTE. Ltd. vs. ACIT held that the mere reference to "misreporting" without specifying the limb of Section 270A attracted or satisfying the ingredients of subsection (9) renders the order imposing penalty u/s 270A(9)(a) manifestly arbitrary. Consequently, the levy of penalty u/s 270A(9)(a) was deleted in favor of the assessee.
The jurisdictional HC in the case of Schneider Electric South Asia (HQ) PTE. Ltd. vs. ACIT held that the mere reference to "misreporting" without specifying the limb of Section 270A attracted or satisfying the ingredients of subsection (9) renders the order imposing penalty u/s 270A(9)(a) manifestly arbitrary. Consequently, the levy of penalty u/s 270A(9)(a) was deleted in favor of the assessee.
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