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 addressed TDS liability on year-end provisions, finding no short deduction under section 201 for excess provisions not paid to vendors. The tribunal held that interest under section 201(1A) cannot be levied on unpaid excess provisions. For actual payments made in the subsequent year, TDS liability is determined on the actual amount paid (Rs. 24,76,17,968/-), with interest calculated from the year-end provision date (31.03.2015) to the date of actual payment. Following precedent in a similar case, the tribunal deleted the interest on unpaid excess provisions and restricted TDS liability to the actual amount disbursed.
The ITAT addressed TDS liability on year-end provisions, finding no short deduction under section 201 for excess provisions not paid to vendors. The tribunal held that interest under section 201(1A) cannot be levied on unpaid excess provisions. For actual payments made in the subsequent year, TDS liability is determined on the actual amount paid (Rs. 24,76,17,968/-), with interest calculated from the year-end provision date (31.03.2015) to the date of actual payment. Following precedent in a similar case, the tribunal deleted the interest on unpaid excess provisions and restricted TDS liability to the actual amount disbursed.
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