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 resolved multiple grounds of appeal concerning insurance-related tax matters. The Tribunal allowed provisions for IBNR/IBNER claims, holding them as ascertainable liabilities based on empirical data rather than contingent liabilities. Amortization of premium paid on securities was decided in favor of revenue, following prior coordinate bench orders. Regarding reinsurance premium to foreign insurers under Section 40(a)(i), ITAT deleted additions and rejected the 15% restriction on NRR payments. Commission paid to non-resident agents was held non-taxable as no direct payments were made. Survey fees to non-residents were deemed non-taxable reimbursements for services performed outside India with no business connection in India, ruling against revenue's Section 40(a)(ia) disallowance.
ITAT resolved multiple grounds of appeal concerning insurance-related tax matters. The Tribunal allowed provisions for IBNR/IBNER claims, holding them as ascertainable liabilities based on empirical data rather than contingent liabilities. Amortization of premium paid on securities was decided in favor of revenue, following prior coordinate bench orders. Regarding reinsurance premium to foreign insurers under Section 40(a)(i), ITAT deleted additions and rejected the 15% restriction on NRR payments. Commission paid to non-resident agents was held non-taxable as no direct payments were made. Survey fees to non-residents were deemed non-taxable reimbursements for services performed outside India with no business connection in India, ruling against revenue's Section 40(a)(ia) disallowance.
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