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 ITAT set aside the order of the Addl./JCIT(A)-1, Coimbatore and remanded the matter for fresh consideration regarding TDS credit claims. While the Tribunal rejected the appellant's contention that no reasons were provided for disallowing TDS credits (as AO/CPC had specifically identified unmatched TDS from four contractors), it noted that Form 26AS downloaded on June 18, 2020, showed all TDS entries. The ITAT directed the appellate authority to reconsider the matter in light of previous assessment years (2009-10 to 2014-15 and 2016-17) where similar claims were accepted with refunds issued. The appellant was instructed to respond to notices and provide supporting documentation without seeking adjournments. Appeal partly allowed for statistical purposes.
The ITAT set aside the order of the Addl./JCIT(A)-1, Coimbatore and remanded the matter for fresh consideration regarding TDS credit claims. While the Tribunal rejected the appellant's contention that no reasons were provided for disallowing TDS credits (as AO/CPC had specifically identified unmatched TDS from four contractors), it noted that Form 26AS downloaded on June 18, 2020, showed all TDS entries. The ITAT directed the appellate authority to reconsider the matter in light of previous assessment years (2009-10 to 2014-15 and 2016-17) where similar claims were accepted with refunds issued. The appellant was instructed to respond to notices and provide supporting documentation without seeking adjournments. Appeal partly allowed for statistical purposes.
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