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 a tax dispute involving TDS liability under Section 194C. The tribunal examined two key issues: (1) food supply bills and (2) business promotion expenses. For food supply transactions, the tribunal determined that GST-subjected food packet supplies do not constitute a service contract, thus Section 194C does not apply. Regarding business promotion expenses, the tribunal referenced a precedent from Ratnagiri Impex Private Limited, which clarified that certain customer facilities do not constitute 'work' under Section 194C. Consequently, the tribunal allowed the assessee's grounds, quashing disallowance of expenses and holding that TDS provisions were not applicable to the specific transactions in question.
ITAT adjudicated a tax dispute involving TDS liability under Section 194C. The tribunal examined two key issues: (1) food supply bills and (2) business promotion expenses. For food supply transactions, the tribunal determined that GST-subjected food packet supplies do not constitute a service contract, thus Section 194C does not apply. Regarding business promotion expenses, the tribunal referenced a precedent from Ratnagiri Impex Private Limited, which clarified that certain customer facilities do not constitute 'work' under Section 194C. Consequently, the tribunal allowed the assessee's grounds, quashing disallowance of expenses and holding that TDS provisions were not applicable to the specific transactions in question.
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