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 ruled on multiple issues in a tax dispute. TPO adjustments regarding Northstar Health Care were deleted following prior precedent. For drug sales pricing adjustments, ALP recomputation was ordered. Provision for rebates written back was deleted based on statutory benefit principles. Addition for restructuring-related provisions was confirmed due to rate differential concerns. Job work charges addition was deleted as genuineness was established. For R&D deduction under s.35(2AB), claim denied due to missing Form 3CL but alternative relief under s.37/32 permitted subject to proper bifurcation. FCCB premium redemption expense disallowed under s.40(a)(i) for non-deduction of TDS, to be allowed in year when TDS is deducted.
ITAT ruled on multiple issues in a tax dispute. TPO adjustments regarding Northstar Health Care were deleted following prior precedent. For drug sales pricing adjustments, ALP recomputation was ordered. Provision for rebates written back was deleted based on statutory benefit principles. Addition for restructuring-related provisions was confirmed due to rate differential concerns. Job work charges addition was deleted as genuineness was established. For R&D deduction under s.35(2AB), claim denied due to missing Form 3CL but alternative relief under s.37/32 permitted subject to proper bifurcation. FCCB premium redemption expense disallowed under s.40(a)(i) for non-deduction of TDS, to be allowed in year when TDS is deducted.
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