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...
The ITAT allowed the appeal of the assessee against the demand raised for short deduction of TDS under section 200A due to non-linking of PAN with Aadhar by the payee. The tribunal observed that the assessee deducted TDS at 1% based on the active status of the seller's PAN at the time of payment, unaware of its inactive status due to delayed PAN-Aadhar linking. Considering that the seller subsequently linked PAN with Aadhar, paid the applicable penalty, and disclosed the income from the transaction in the return, the tribunal emphasized the legislative intent to ensure compliance by the payee, not to penalize the payer for unintentional lapses. Further, the extended timeline for PAN-Aadhar linking supported the assessee's position. Consequently, the demand for short deduction of TDS at 19% was quashed, and the appeal was allowed.
The ITAT allowed the appeal of the assessee against the demand raised for short deduction of TDS under section 200A due to non-linking of PAN with Aadhar by the payee. The tribunal observed that the assessee deducted TDS at 1% based on the active status of the seller's PAN at the time of payment, unaware of its inactive status due to delayed PAN-Aadhar linking. Considering that the seller subsequently linked PAN with Aadhar, paid the applicable penalty, and disclosed the income from the transaction in the return, the tribunal emphasized the legislative intent to ensure compliance by the payee, not to penalize the payer for unintentional lapses. Further, the extended timeline for PAN-Aadhar linking supported the assessee's position. Consequently, the demand for short deduction of TDS at 19% was quashed, and the appeal was allowed.
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