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 ITAT held that the TPO shall consider 1% rate as the arm's length price (ALP) for the international transaction involving issuance of Stand-by Letter of Credit (SBLC) to the associated enterprise (AE). The revenue expenditure claimed by the assessee, which exceeded the amount quantified by the DSIR, should be allowed as deduction u/s 37(1) after allowing the eligible portion u/s 35(2AB), as the AO erred in not examining whether the differential amount was for business purposes.
The ITAT held that the TPO shall consider 1% rate as the arm's length price (ALP) for the international transaction involving issuance of Stand-by Letter of Credit (SBLC) to the associated enterprise (AE). The revenue expenditure claimed by the assessee, which exceeded the amount quantified by the DSIR, should be allowed as deduction u/s 37(1) after allowing the eligible portion u/s 35(2AB), as the AO erred in not examining whether the differential amount was for business purposes.
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