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 regarding an IT company's tax assessment. The Tribunal left open the determination of whether the assessee operates as a KPO or software developer, citing insufficient reasoning from TPO/DRP. On corporate guarantee fees, ITAT directed benchmarking at 0.53% limited to actual guarantee periods. Regarding TDS under s.192, the matter of salary expense disallowance was remanded to AO for fresh verification of additional evidence submitted by assessee. The Tribunal set aside the 30% disallowance under s.40(a)(ia), directing AO to examine documentation supporting non-deduction of TDS where employee incomes fell below taxable threshold. Case remanded for limited review of salary payments and TDS compliance under s.192.
ITAT addressed multiple issues regarding an IT company's tax assessment. The Tribunal left open the determination of whether the assessee operates as a KPO or software developer, citing insufficient reasoning from TPO/DRP. On corporate guarantee fees, ITAT directed benchmarking at 0.53% limited to actual guarantee periods. Regarding TDS under s.192, the matter of salary expense disallowance was remanded to AO for fresh verification of additional evidence submitted by assessee. The Tribunal set aside the 30% disallowance under s.40(a)(ia), directing AO to examine documentation supporting non-deduction of TDS where employee incomes fell below taxable threshold. Case remanded for limited review of salary payments and TDS compliance under s.192.
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