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 ruled on multiple transfer pricing and tax-related issues. Key outcomes include: directing TPO to exclude certain comparables from transfer pricing analysis, allowing deduction of forex derivative mark-to-market losses, instructing AO to reexamine disallowances related to bad debts and business expenses, and confirming non-applicability of MAT provisions for banking institutions. The tribunal generally provided directives for reassessment, emphasizing compliance with legal precedents and granting opportunities for the assessee to substantiate claims. Most disputed items were remanded for fresh examination in accordance with established legal principles and Supreme Court interpretations.
ITAT ruled on multiple transfer pricing and tax-related issues. Key outcomes include: directing TPO to exclude certain comparables from transfer pricing analysis, allowing deduction of forex derivative mark-to-market losses, instructing AO to reexamine disallowances related to bad debts and business expenses, and confirming non-applicability of MAT provisions for banking institutions. The tribunal generally provided directives for reassessment, emphasizing compliance with legal precedents and granting opportunities for the assessee to substantiate claims. Most disputed items were remanded for fresh examination in accordance with established legal principles and Supreme Court interpretations.
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