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 the CIT(A)'s rejection of Revenue's transfer pricing adjustments, finding the assessee to be a captive manufacturer and dismissing Revenue's appeals on gross margin and management support service additions; those orders stand. ITAT remits the disputed additional depreciation claim to the AO for recalculation and allowance of the correct amount, permitting the assessee to submit supporting particulars and be heard. The AO is directed to verify and recompute the section 14A/Rule 8D disallowance. Drawings used in motorcycle design are held to qualify as "plant" for section 32AC, and the section 32AC deduction is allowed; claims for additional depreciation under section 32(1)(iia) are admitted and remitted to the AO for fresh, reasoned adjudication.
ITAT upholds the CIT(A)'s rejection of Revenue's transfer pricing adjustments, finding the assessee to be a captive manufacturer and dismissing Revenue's appeals on gross margin and management support service additions; those orders stand. ITAT remits the disputed additional depreciation claim to the AO for recalculation and allowance of the correct amount, permitting the assessee to submit supporting particulars and be heard. The AO is directed to verify and recompute the section 14A/Rule 8D disallowance. Drawings used in motorcycle design are held to qualify as "plant" for section 32AC, and the section 32AC deduction is allowed; claims for additional depreciation under section 32(1)(iia) are admitted and remitted to the AO for fresh, reasoned adjudication.
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