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...
For benchmarking research support services, a company selected as a comparable was held to fail the turnover filter since its turnover was only INR 3.65 crores; the AO/TPO was directed to rework the arm's length analysis by applying filters correctly and excluding that company, with consequent TP adjustment, if any, to be recomputed. On disallowance of employees' PF contribution for delayed credit, where the assessee had remitted the amount and it was debited from its bank within the stipulated date but credit to EPFO was delayed due to technical glitches beyond its control, the disallowance was deleted and the ratio in Checkmate Services was held inapplicable, resulting in the appeal being allowed. - ITAT
For benchmarking research support services, a company selected as a comparable was held to fail the turnover filter since its turnover was only INR 3.65 crores; the AO/TPO was directed to rework the arm's length analysis by applying filters correctly and excluding that company, with consequent TP adjustment, if any, to be recomputed. On disallowance of employees' PF contribution for delayed credit, where the assessee had remitted the amount and it was debited from its bank within the stipulated date but credit to EPFO was delayed due to technical glitches beyond its control, the disallowance was deleted and the ratio in Checkmate Services was held inapplicable, resulting in the appeal being allowed. - ITAT
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