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...
Foreign exchange fluctuation arising from international transactions for provision of specified products/services under a cost-plus arrangement was held to be operating in nature, since the gain/loss directly emanated from trading items linked to the controlled transactions; accordingly, treating the foreign exchange loss as non-operating cost for TP computation was impermissible and the adjustment on that basis was set aside. On benchmarking, the challenge to the price applied/proposed in an uncontrolled transaction and the related selection/exclusion of comparables was decided in favour of the assessee, resulting in deletion/relief from the impugned TP adjustments. - HC
Foreign exchange fluctuation arising from international transactions for provision of specified products/services under a cost-plus arrangement was held to be operating in nature, since the gain/loss directly emanated from trading items linked to the controlled transactions; accordingly, treating the foreign exchange loss as non-operating cost for TP computation was impermissible and the adjustment on that basis was set aside. On benchmarking, the challenge to the price applied/proposed in an uncontrolled transaction and the related selection/exclusion of comparables was decided in favour of the assessee, resulting in deletion/relief from the impugned TP adjustments. - HC
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