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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 upheld that a unilateral APA, covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16, applies to AY 2013-14 for the issue of reimbursement of AMP expenses; accordingly, appeals of the assessee and revenue on that issue were dismissed. On alleged TDS defaults under s.195 and consequent disallowance u/s 40(a)(i) for payments to non-residents, the ITAT found material facts regarding the nature of services, cost-plus markup and the "make available" contention were not on record; the claims warranted re-verification. The ITAT set aside the AO's and CIT(A)'s orders and remitted the matter to the AO for fresh adjudication in accordance with law.
The ITAT upheld that a unilateral APA, covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16, applies to AY 2013-14 for the issue of reimbursement of AMP expenses; accordingly, appeals of the assessee and revenue on that issue were dismissed. On alleged TDS defaults under s.195 and consequent disallowance u/s 40(a)(i) for payments to non-residents, the ITAT found material facts regarding the nature of services, cost-plus markup and the "make available" contention were not on record; the claims warranted re-verification. The ITAT set aside the AO's and CIT(A)'s orders and remitted the matter to the AO for fresh adjudication in accordance with law.
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