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...
Transfer pricing adjustment on royalty payment to an AE was sustained by the DRP by adopting an arm's length royalty rate of 53% based on an earlier APA; however, since the taxpayer had executed a unilateral APA with CBDT covering the royalty transaction and had filed a modified return enhancing income accordingly, the AO was directed to give effect to the APA and reframe the order. Deduction under s. 80G for donations forming part of CSR spend was disallowed on grounds of invalid donation certificates and impermissible double benefit, but applying binding and coordinate precedents, s. 80G deduction was held allowable notwithstanding CSR claim, and the disallowance was deleted. - ITAT
Transfer pricing adjustment on royalty payment to an AE was sustained by the DRP by adopting an arm's length royalty rate of 53% based on an earlier APA; however, since the taxpayer had executed a unilateral APA with CBDT covering the royalty transaction and had filed a modified return enhancing income accordingly, the AO was directed to give effect to the APA and reframe the order. Deduction under s. 80G for donations forming part of CSR spend was disallowed on grounds of invalid donation certificates and impermissible double benefit, but applying binding and coordinate precedents, s. 80G deduction was held allowable notwithstanding CSR claim, and the disallowance was deleted. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
