Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
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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...
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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 partially allowed the assessee's appeal regarding transfer pricing adjustment for corporate guarantee, directing AO to adopt guarantee commission at 0.5% instead of 2%. On AMP expenses, the matter was remanded for fresh examination to determine existence of international transaction. The Tribunal confirmed TP adjustment for royalty income, finding the deferment was an afterthought to postpone tax liability. Disallowance under SS14A was partly allowed, directing recalculation under Rule 8D(2)(iii) based only on dividend-yielding investments. Export agency commission was held not subject to TDS as it didn't constitute technical services. The Tribunal allowed deduction of amortized premium on forward contracts and foreign exchange loss on ECB repayment. Additional depreciation claim on assets put to use in previous year was also allowed.
The ITAT partially allowed the assessee's appeal regarding transfer pricing adjustment for corporate guarantee, directing AO to adopt guarantee commission at 0.5% instead of 2%. On AMP expenses, the matter was remanded for fresh examination to determine existence of international transaction. The Tribunal confirmed TP adjustment for royalty income, finding the deferment was an afterthought to postpone tax liability. Disallowance under SS14A was partly allowed, directing recalculation under Rule 8D(2)(iii) based only on dividend-yielding investments. Export agency commission was held not subject to TDS as it didn't constitute technical services. The Tribunal allowed deduction of amortized premium on forward contracts and foreign exchange loss on ECB repayment. Additional depreciation claim on assets put to use in previous year was also allowed.
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