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 transfer pricing and tax deduction matters. In the TP adjustment, the tribunal remanded the case to the TPO/AO to determine arm's length pricing using TNNM method, with a 3% tolerance range for operating margin. For weighted deduction under section 35(2AB), the tribunal allowed the assessee's claim consistently with a prior year's order. Regarding additional depreciation under section 32(iia), the tribunal directed the AO to comply with DRP's instructions and allow the depreciation claim, criticizing the AO's failure to implement previous directions. The decision emphasizes procedural compliance and consistent interpretation of tax regulations.
The ITAT addressed transfer pricing and tax deduction matters. In the TP adjustment, the tribunal remanded the case to the TPO/AO to determine arm's length pricing using TNNM method, with a 3% tolerance range for operating margin. For weighted deduction under section 35(2AB), the tribunal allowed the assessee's claim consistently with a prior year's order. Regarding additional depreciation under section 32(iia), the tribunal directed the AO to comply with DRP's instructions and allow the depreciation claim, criticizing the AO's failure to implement previous directions. The decision emphasizes procedural compliance and consistent interpretation of tax regulations.
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