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...
HC determined that the Permanent Establishment (PE) status remained unresolved between jurisdictional tax authorities despite mutual agreement attempts. The MAP determination in 2017 was not properly communicated to the Tribunal, which continued proceedings for Assessment Years 2006-07 and 2008-09 based on incomplete information. The court set aside the existing orders, mandating the Tribunal to comprehensively re-examine the PE issue and tax implications, ensuring a fresh and thorough adjudication of the unresolved taxation matters.
HC determined that the Permanent Establishment (PE) status remained unresolved between jurisdictional tax authorities despite mutual agreement attempts. The MAP determination in 2017 was not properly communicated to the Tribunal, which continued proceedings for Assessment Years 2006-07 and 2008-09 based on incomplete information. The court set aside the existing orders, mandating the Tribunal to comprehensively re-examine the PE issue and tax implications, ensuring a fresh and thorough adjudication of the unresolved taxation matters.
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