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...
Reimbursements received from Indian group entities for actual salary costs of seconded employees could not be taxed as fees for technical services under section 9(1)(vii) and Article 12(4) of the India-Japan DTAA because the contracts and appointment letters established an employer-employee relationship between the secondees and the Indian entities, making the payments in substance salary and not consideration for rendering technical services; accordingly, the reimbursements were not recharacterizable as FTS and the addition was deleted, allowing the appeal. - ITAT
Reimbursements received from Indian group entities for actual salary costs of seconded employees could not be taxed as fees for technical services under section 9(1)(vii) and Article 12(4) of the India-Japan DTAA because the contracts and appointment letters established an employer-employee relationship between the secondees and the Indian entities, making the payments in substance salary and not consideration for rendering technical services; accordingly, the reimbursements were not recharacterizable as FTS and the addition was deleted, allowing the appeal. - ITAT
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