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...
HC determined payments made to IGSPT for call center services were subject to TDS under section 194C, not 194J. The agreement between parties involved basic call center operations performed by undergraduates/graduates following prescribed guidelines, rather than professional/technical services. Service executives handled subscriber complaints without requiring specialized expertise. CIT(A) and ITAT's concurrent findings established the services were routine operational support, not technical/professional in nature. Additionally, service providers had already paid appropriate taxes through advance tax/self-assessment. HC found no question of law arose, as factual findings were supported by agreement terms, staff qualifications, and work nature documentation. Original assessment order requiring TDS under section 194J was not sustained.
HC determined payments made to IGSPT for call center services were subject to TDS under section 194C, not 194J. The agreement between parties involved basic call center operations performed by undergraduates/graduates following prescribed guidelines, rather than professional/technical services. Service executives handled subscriber complaints without requiring specialized expertise. CIT(A) and ITAT's concurrent findings established the services were routine operational support, not technical/professional in nature. Additionally, service providers had already paid appropriate taxes through advance tax/self-assessment. HC found no question of law arose, as factual findings were supported by agreement terms, staff qualifications, and work nature documentation. Original assessment order requiring TDS under section 194J was not sustained.
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