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...
ITAT addressed multiple issues in a transfer pricing and tax deduction appeal. On interest-free loans to AE, the matter was remanded for verification of surplus funds and nexus with borrowed loans. Corporate guarantee fee was benchmarked at 0.5%. Depreciation on leasehold property rights was remitted following Madras HC precedent. Section 80G deduction for CSR expenses was remanded for de novo consideration. Section 14A disallowance was directed to consider only investments yielding exempt income. TP adjustment on debenture interest was to be benchmarked based on comparable international transactions at 1.76% rather than domestic rates. The appeal was partly allowed with specific directions for reassessment of each issue according to prescribed parameters.
ITAT addressed multiple issues in a transfer pricing and tax deduction appeal. On interest-free loans to AE, the matter was remanded for verification of surplus funds and nexus with borrowed loans. Corporate guarantee fee was benchmarked at 0.5%. Depreciation on leasehold property rights was remitted following Madras HC precedent. Section 80G deduction for CSR expenses was remanded for de novo consideration. Section 14A disallowance was directed to consider only investments yielding exempt income. TP adjustment on debenture interest was to be benchmarked based on comparable international transactions at 1.76% rather than domestic rates. The appeal was partly allowed with specific directions for reassessment of each issue according to prescribed parameters.
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