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 held that assessee was not liable for TDS default under Section 201(1)/201(1A) regarding immovable property transactions. For property purchased on 30.01.2018, where consideration paid to each of four co-owners was Rs. 40,25,000 (below Rs. 50 lakhs threshold), no TDS deduction was required under Section 194IA. The amended provision requiring aggregate consideration of all transferors applies only from 01.10.2024. Similarly, for property purchased on 30.08.2017 with consideration below Rs. 50 lakhs, stamp duty value consideration was not applicable before 01.04.2022. However, regarding audit fee payment, assessee was correctly treated as in default under Section 194J. Matter remanded to TDS AO for verification of recipient's tax payment and restricting interest computation from deduction date to recipient's return filing date. Demands under Section 201(1)/201(1A) for property transactions deleted.
ITAT held that assessee was not liable for TDS default under Section 201(1)/201(1A) regarding immovable property transactions. For property purchased on 30.01.2018, where consideration paid to each of four co-owners was Rs. 40,25,000 (below Rs. 50 lakhs threshold), no TDS deduction was required under Section 194IA. The amended provision requiring aggregate consideration of all transferors applies only from 01.10.2024. Similarly, for property purchased on 30.08.2017 with consideration below Rs. 50 lakhs, stamp duty value consideration was not applicable before 01.04.2022. However, regarding audit fee payment, assessee was correctly treated as in default under Section 194J. Matter remanded to TDS AO for verification of recipient's tax payment and restricting interest computation from deduction date to recipient's return filing date. Demands under Section 201(1)/201(1A) for property transactions deleted.
Note: It is a system-generated summary and is for quick reference only.