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 upholds that TP adjustments in respect of international transactions for export of finished goods and royalty payments to an AE are deleted: ALP may be benchmarked by TNMM where CUP is inappropriate due to factual/geographical differences, following a co-ordinate bench decision in the assessee's own case. The tribunal directs rectification of an inadvertent addition of TP adjustments in the computation of book profit under s.115JB to align with the final order. Claims for credit under s.115JAA and TDS are remitted to the AO for verification and appropriate grant. Interest under s.234C is to be computed on returned income after accounting taxes paid. Deduction u/s.80G for donations from CSR funds is allowed where statutory conditions are satisfied.
ITAT upholds that TP adjustments in respect of international transactions for export of finished goods and royalty payments to an AE are deleted: ALP may be benchmarked by TNMM where CUP is inappropriate due to factual/geographical differences, following a co-ordinate bench decision in the assessee's own case. The tribunal directs rectification of an inadvertent addition of TP adjustments in the computation of book profit under s.115JB to align with the final order. Claims for credit under s.115JAA and TDS are remitted to the AO for verification and appropriate grant. Interest under s.234C is to be computed on returned income after accounting taxes paid. Deduction u/s.80G for donations from CSR funds is allowed where statutory conditions are satisfied.
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