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...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT addressed transfer pricing adjustment regarding business support services between associated enterprises. TPO rejected assessee's TNMM method and entity-level benchmarking, favoring CUP method. Tribunal found insufficient evidence demonstrating actual service receipt, noting mere documentation (master agreement, work statements, invoices, emails) inadequate to establish genuine service provision. Tribunal determined services appeared to be shareholder cost allocations rather than distinct business services. Due to inadequate documentation distinguishing between cost allocation and actual services rendered, matter remanded to TPO for de-novo adjudication. Issue restored for fresh determination under transfer pricing provisions without prejudice from prior findings. Appeal allowed for statistical purposes.
ITAT addressed transfer pricing adjustment regarding business support services between associated enterprises. TPO rejected assessee's TNMM method and entity-level benchmarking, favoring CUP method. Tribunal found insufficient evidence demonstrating actual service receipt, noting mere documentation (master agreement, work statements, invoices, emails) inadequate to establish genuine service provision. Tribunal determined services appeared to be shareholder cost allocations rather than distinct business services. Due to inadequate documentation distinguishing between cost allocation and actual services rendered, matter remanded to TPO for de-novo adjudication. Issue restored for fresh determination under transfer pricing provisions without prejudice from prior findings. Appeal allowed for statistical purposes.
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