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 adjudicated transfer pricing and tax assessment matters involving a software services company. The tribunal directed inclusion of Sasken Communication Technologies Ltd in comparable companies list, while excluding Wipro, Tata Elxsi, Infosys, and Larsen & Toubro Infotech due to segmental reporting disparities. On Rule 14A disallowance, the tribunal held that investments from non-interest bearing funds do not warrant interest expenditure disallowance. The tribunal restored the disallowance computation to the Assessing Officer, noting only dividend-yielding investments should be considered. Regarding section 143(1) adjustments, the tribunal advised the assessee to seek remedy through separate proceedings, finding the current forum inappropriate for addressing such grievances.
ITAT adjudicated transfer pricing and tax assessment matters involving a software services company. The tribunal directed inclusion of Sasken Communication Technologies Ltd in comparable companies list, while excluding Wipro, Tata Elxsi, Infosys, and Larsen & Toubro Infotech due to segmental reporting disparities. On Rule 14A disallowance, the tribunal held that investments from non-interest bearing funds do not warrant interest expenditure disallowance. The tribunal restored the disallowance computation to the Assessing Officer, noting only dividend-yielding investments should be considered. Regarding section 143(1) adjustments, the tribunal advised the assessee to seek remedy through separate proceedings, finding the current forum inappropriate for addressing such grievances.
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