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 multiple transfer pricing disputes, rendering key holdings: The tribunal invalidated adjustments related to advertising and marketing (AMP) expenses, following precedential high court rulings that such expenditures do not constitute international transactions. Protective adjustments under Bright Line Test (BLT) and Transactional Net Margin Method (TNMM) were deleted. Compulsorily Convertible Debentures (CCDs) were affirmed as debt instruments, rejecting tax authority's recharacterization as equity. The tribunal also found improper transfer pricing methodology in interest receivables calculation, deleting upward adjustments. Regarding resale of designated services, the tribunal set aside Dispute Resolution Panel's (DRP) findings and directed reconsideration of comparable selection in accordance with legal principles.
ITAT adjudicated multiple transfer pricing disputes, rendering key holdings: The tribunal invalidated adjustments related to advertising and marketing (AMP) expenses, following precedential high court rulings that such expenditures do not constitute international transactions. Protective adjustments under Bright Line Test (BLT) and Transactional Net Margin Method (TNMM) were deleted. Compulsorily Convertible Debentures (CCDs) were affirmed as debt instruments, rejecting tax authority's recharacterization as equity. The tribunal also found improper transfer pricing methodology in interest receivables calculation, deleting upward adjustments. Regarding resale of designated services, the tribunal set aside Dispute Resolution Panel's (DRP) findings and directed reconsideration of comparable selection in accordance with legal principles.
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