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...
The HC ruled in favor of the assessee regarding Asset Reconstruction Cost (ARC) provisioning, holding it qualified as a present obligation under AS 29 rather than a contingent liability. The Court determined the contractual obligation to repair and restore premises constituted an ascertainable liability that was properly provisioned for. The HC rejected the tax authorities' view that only ascertained liabilities could be provisioned. Regarding interest deduction under Section 36(1)(iii), the Court clarified that the provision's proviso merely disallows interest during the period between borrowing and when an asset is put to use for business extension. The matter was remanded to the AO to examine whether cell sites were actually put to use and whether funds came from a common pool.
The HC ruled in favor of the assessee regarding Asset Reconstruction Cost (ARC) provisioning, holding it qualified as a present obligation under AS 29 rather than a contingent liability. The Court determined the contractual obligation to repair and restore premises constituted an ascertainable liability that was properly provisioned for. The HC rejected the tax authorities' view that only ascertained liabilities could be provisioned. Regarding interest deduction under Section 36(1)(iii), the Court clarified that the provision's proviso merely disallows interest during the period between borrowing and when an asset is put to use for business extension. The matter was remanded to the AO to examine whether cell sites were actually put to use and whether funds came from a common pool.
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