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 set aside and restored multiple issues to the file of the AO. The DRP's LIBOR+350 bps rate is held prima facie appropriate, but the AO is directed to require the assessee to benchmark the outstanding receivable by reference to the currency of invoicing and to determine ALP of the international transaction under s.92CA, applying suitable mark-up or reduction for transaction-specific risk; the assessee may argue working-capital adjustments for software/ITeS segments. A double addition made at s.143(1) and again in the final order is to be deleted. The AO must use the disclosed book profit of Rs.118,10,19,785 for s.115JB computation. Donations qualify for deduction under s.80G; AO to allow.
The ITAT set aside and restored multiple issues to the file of the AO. The DRP's LIBOR+350 bps rate is held prima facie appropriate, but the AO is directed to require the assessee to benchmark the outstanding receivable by reference to the currency of invoicing and to determine ALP of the international transaction under s.92CA, applying suitable mark-up or reduction for transaction-specific risk; the assessee may argue working-capital adjustments for software/ITeS segments. A double addition made at s.143(1) and again in the final order is to be deleted. The AO must use the disclosed book profit of Rs.118,10,19,785 for s.115JB computation. Donations qualify for deduction under s.80G; AO to allow.
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