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 upheld deletion of penalties under s271(1)(c) and s270A regarding non-deduction of TDS on External Development Charges paid to HUDA. While assessee did not contest the s40(a)(ia) disallowance, they provided reasonable explanation that legal clarity was lacking on TDS applicability to EDC payments at the relevant time. No evidence suggested non-genuine payments or income concealment. Mere non-compliance with TDS provisions does not constitute concealment or furnishing inaccurate income particulars. Making incorrect legal claims does not amount to providing inaccurate details, following Reliance Petroproducts precedent. CIT(A)'s order deleting both penalties was upheld, ruling in assessee's favor.
ITAT upheld deletion of penalties under s271(1)(c) and s270A regarding non-deduction of TDS on External Development Charges paid to HUDA. While assessee did not contest the s40(a)(ia) disallowance, they provided reasonable explanation that legal clarity was lacking on TDS applicability to EDC payments at the relevant time. No evidence suggested non-genuine payments or income concealment. Mere non-compliance with TDS provisions does not constitute concealment or furnishing inaccurate income particulars. Making incorrect legal claims does not amount to providing inaccurate details, following Reliance Petroproducts precedent. CIT(A)'s order deleting both penalties was upheld, ruling in assessee's favor.
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