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 directed exclusion of several comparables for transfer pricing adjustments in software development services (Infosys Ltd, Persistent Systems Ltd, Tata Elexi Ltd, Bodhtree Consulting Ltd) and ITeS (Eclerx Services Ltd, Cosmic Global Ltd, Accentia Technologies Ltd, Infosys BPO Ltd) due to functional differences and lack of segmental information. The Tribunal allowed deductions under s.10A for UB Plaza Unit, Titanium STPI Unit, and the unit acquired from Reuters India, following previous favorable decisions. The issue of depreciation on goodwill was restored to AO for de novo adjudication. ITAT upheld DRP's direction to exclude communication and travel expenses from both export and total turnover while computing s.10A deduction, following HCL Technologies Ltd precedent, and affirmed deletion of software disallowance under s.40(a)(ia) per Tally Solutions ruling.
ITAT directed exclusion of several comparables for transfer pricing adjustments in software development services (Infosys Ltd, Persistent Systems Ltd, Tata Elexi Ltd, Bodhtree Consulting Ltd) and ITeS (Eclerx Services Ltd, Cosmic Global Ltd, Accentia Technologies Ltd, Infosys BPO Ltd) due to functional differences and lack of segmental information. The Tribunal allowed deductions under s.10A for UB Plaza Unit, Titanium STPI Unit, and the unit acquired from Reuters India, following previous favorable decisions. The issue of depreciation on goodwill was restored to AO for de novo adjudication. ITAT upheld DRP's direction to exclude communication and travel expenses from both export and total turnover while computing s.10A deduction, following HCL Technologies Ltd precedent, and affirmed deletion of software disallowance under s.40(a)(ia) per Tally Solutions ruling.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
