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 directed exclusion of MPS, Manipal, Integra, and Wizard from the final comparable set for TP adjustment in ITES services, while including Bhilwara and UBM for marketing support services, with recomputation accordingly. For engineering services, the AO/TPO was instructed to follow the Tribunal's earlier order for AY 2017-18. In the manufacturing segment, the Tribunal accepted the assessee's economic adjustments under Rule 10B(1)(e) for low capacity utilization, remanding for appropriate margin adjustments and evidence submission. No disallowance under section 14A was warranted as no exempt income arose during the year. The addition under section 36(1)(va) for delayed employee contributions was upheld. The disallowance under section 40(a)(i) relating to TDS on salary paid to a foreign employee was set aside, as salary payments were covered under section 40(a)(iii) and appropriate tax was deducted under section 192, not section 195.
The ITAT directed exclusion of MPS, Manipal, Integra, and Wizard from the final comparable set for TP adjustment in ITES services, while including Bhilwara and UBM for marketing support services, with recomputation accordingly. For engineering services, the AO/TPO was instructed to follow the Tribunal's earlier order for AY 2017-18. In the manufacturing segment, the Tribunal accepted the assessee's economic adjustments under Rule 10B(1)(e) for low capacity utilization, remanding for appropriate margin adjustments and evidence submission. No disallowance under section 14A was warranted as no exempt income arose during the year. The addition under section 36(1)(va) for delayed employee contributions was upheld. The disallowance under section 40(a)(i) relating to TDS on salary paid to a foreign employee was set aside, as salary payments were covered under section 40(a)(iii) and appropriate tax was deducted under section 192, not section 195.
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