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 overturned PCIT's revision order under s.263 concerning multiple issues in a telecom company's assessment. Key rulings: Interest/penalty on delayed license fee payments held as revenue expenditure, being compensatory rather than capital in nature. Carry forward of accumulated losses under s.72A allowed as demerger conditions were satisfied. No s.56(2)(x) implications arose on business acquisition through court-approved demerger. Transfer pricing adjustment directive rejected as AO had followed jurisdictional High Court precedent. Claims regarding TDS on bandwidth charges to non-residents, s.14A disallowance, depreciation verification, and s.269SS compliance were found to have been adequately examined during original assessment. ITAT emphasized that PCIT's revision powers cannot be exercised where AO has conducted proper inquiry, even if conclusions differ.
ITAT overturned PCIT's revision order under s.263 concerning multiple issues in a telecom company's assessment. Key rulings: Interest/penalty on delayed license fee payments held as revenue expenditure, being compensatory rather than capital in nature. Carry forward of accumulated losses under s.72A allowed as demerger conditions were satisfied. No s.56(2)(x) implications arose on business acquisition through court-approved demerger. Transfer pricing adjustment directive rejected as AO had followed jurisdictional High Court precedent. Claims regarding TDS on bandwidth charges to non-residents, s.14A disallowance, depreciation verification, and s.269SS compliance were found to have been adequately examined during original assessment. ITAT emphasized that PCIT's revision powers cannot be exercised where AO has conducted proper inquiry, even if conclusions differ.
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