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...
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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 dismissed revenue's appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure disallowance under section 69C. CIT(A)'s deletion of additions was upheld after assessee provided documentary evidence including Form 26AS showing TDS of Rs. 5,29,04,162/- deducted on payments to foreign entity. Regarding software expenses, ITAT confirmed CIT(A)'s finding that IT support charges constituted revenue expenditure rather than capital expenditure, as payments were for yearly renewable software licenses without acquiring proprietary rights. Revenue failed to controvert factual position with supporting evidence, resulting in dismissal of all grounds.
ITAT dismissed revenue's appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure disallowance under section 69C. CIT(A)'s deletion of additions was upheld after assessee provided documentary evidence including Form 26AS showing TDS of Rs. 5,29,04,162/- deducted on payments to foreign entity. Regarding software expenses, ITAT confirmed CIT(A)'s finding that IT support charges constituted revenue expenditure rather than capital expenditure, as payments were for yearly renewable software licenses without acquiring proprietary rights. Revenue failed to controvert factual position with supporting evidence, resulting in dismissal of all grounds.
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