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 HC dismissed Revenue's appeal and upheld the Tribunal's orders: it affirmed that, in light of the SC precedent, the assessee is entitled to deduction under s.80IA(4) for power generated for captive consumption and that the market value may be determined by reference to comparable State Electricity Board rates, yielding a higher deduction where profits are higher. On interest disallowances under s.36(1)(iii) and s.14A, the HC agreed with the Tribunal that the blanket 10% disallowance was impermissible where borrowed funds were not shown to finance dividend-earning investments, and sustained the Tribunal's factual disallowance of Rs.91.80 lakh; it also accepted the consensual Rs.5 lakh disallowance in respect of other administrative expenses.
The HC dismissed Revenue's appeal and upheld the Tribunal's orders: it affirmed that, in light of the SC precedent, the assessee is entitled to deduction under s.80IA(4) for power generated for captive consumption and that the market value may be determined by reference to comparable State Electricity Board rates, yielding a higher deduction where profits are higher. On interest disallowances under s.36(1)(iii) and s.14A, the HC agreed with the Tribunal that the blanket 10% disallowance was impermissible where borrowed funds were not shown to finance dividend-earning investments, and sustained the Tribunal's factual disallowance of Rs.91.80 lakh; it also accepted the consensual Rs.5 lakh disallowance in respect of other administrative expenses.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
