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 dismissed the revenue's grounds challenging classification of expenditures on dies, moulds, jigs, fixtures and software as revenue in nature and allowable as deductions; penalty receipts from suppliers were held to be capital receipts and that ground was dismissed. The Tribunal directed deletion of impugned additions, upheld proportionate amortisation of non-refundable premium on 99-year leasehold land, and sustained prior-period charging of crystallised liabilities. Section 80IA deduction was allowed without adjustment for pre-assessment year depreciation and losses. Section 14A disallowance was deleted except administrative disallowance limited to 2% of exempt income. Transfer-pricing and doubtful-debts issues were remitted to AO/TPO for fresh consideration in accordance with law.
ITAT dismissed the revenue's grounds challenging classification of expenditures on dies, moulds, jigs, fixtures and software as revenue in nature and allowable as deductions; penalty receipts from suppliers were held to be capital receipts and that ground was dismissed. The Tribunal directed deletion of impugned additions, upheld proportionate amortisation of non-refundable premium on 99-year leasehold land, and sustained prior-period charging of crystallised liabilities. Section 80IA deduction was allowed without adjustment for pre-assessment year depreciation and losses. Section 14A disallowance was deleted except administrative disallowance limited to 2% of exempt income. Transfer-pricing and doubtful-debts issues were remitted to AO/TPO for fresh consideration in accordance with law.
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