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...
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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...
HC dismissed the revenue's ALP adjustment in respect of advertising, marketing and promotional (AMP) expenses, holding that the addition was precluded by the HC's prior decision in the taxpayer's own case, which was followed by the tribunal; consequently no substantive or protective addition could be sustained on this score. Separately, HC held that the amendment to section 14A of the Act read with Rule 8D cannot be construed as retrospective where it operates to alter the pre-existing legal position despite being framed "for removal of doubts"; such language does not permit retroactive application to change settled law.
HC dismissed the revenue's ALP adjustment in respect of advertising, marketing and promotional (AMP) expenses, holding that the addition was precluded by the HC's prior decision in the taxpayer's own case, which was followed by the tribunal; consequently no substantive or protective addition could be sustained on this score. Separately, HC held that the amendment to section 14A of the Act read with Rule 8D cannot be construed as retrospective where it operates to alter the pre-existing legal position despite being framed "for removal of doubts"; such language does not permit retroactive application to change settled law.
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