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 directed exclusion of two specified comparables from the TP benchmarking set for software development services, resulting in the taxpayer's margin of 11.88% falling within the ±3% range and negating the adjustment. The Tribunal deleted the TP adjustment for intra-group advertisement, marketing and promotion expenses, holding them not to be an international transaction. The Tribunal directed exclusion of a particular comparable in relation to contract R&D services. Disallowance of interest paid to an MSME and deemed income under s.41(1) was restored to the file of the AO for fresh adjudication after affording opportunity of hearing. Disallowance of finance-lease rentals was rejected consistent with prior bench rulings (owner: depreciation; user: rent). Issues under ss.234A/234B and short TDS/TCS credit were remitted to the AO for fresh decision.
ITAT directed exclusion of two specified comparables from the TP benchmarking set for software development services, resulting in the taxpayer's margin of 11.88% falling within the ±3% range and negating the adjustment. The Tribunal deleted the TP adjustment for intra-group advertisement, marketing and promotion expenses, holding them not to be an international transaction. The Tribunal directed exclusion of a particular comparable in relation to contract R&D services. Disallowance of interest paid to an MSME and deemed income under s.41(1) was restored to the file of the AO for fresh adjudication after affording opportunity of hearing. Disallowance of finance-lease rentals was rejected consistent with prior bench rulings (owner: depreciation; user: rent). Issues under ss.234A/234B and short TDS/TCS credit were remitted to the AO for fresh decision.
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