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 upheld the disallowance of a claimed "depreciation" recharge for occupancy expenses, finding the taxpayer neither owned nor expended on the leasehold asset and holding such recharges non-deductible under s.32/s.37(1). The Tribunal deleted the addition relating to RSU/ESOP expenditure. An intimation addition concerning leave encashment/bonus was remitted for AO action on the pending s.154 rectification. CCDs issued to associated enterprises were held to be debt until conversion; interest thereon is prima facie allowable and transfer-pricing treatment was restored to the TPO/AO for de novo benchmarking and ALP determination (section 94B contentions kept open). TDS credit and s.234A/234B interest issues were remitted to the AO for verification and consequential action in accordance with law.
ITAT upheld the disallowance of a claimed "depreciation" recharge for occupancy expenses, finding the taxpayer neither owned nor expended on the leasehold asset and holding such recharges non-deductible under s.32/s.37(1). The Tribunal deleted the addition relating to RSU/ESOP expenditure. An intimation addition concerning leave encashment/bonus was remitted for AO action on the pending s.154 rectification. CCDs issued to associated enterprises were held to be debt until conversion; interest thereon is prima facie allowable and transfer-pricing treatment was restored to the TPO/AO for de novo benchmarking and ALP determination (section 94B contentions kept open). TDS credit and s.234A/234B interest issues were remitted to the AO for verification and consequential action in accordance with law.
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