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...
On TP adjustment relating to computation of operating margins of selected comparables, the directions were held non-speaking because the panel addressed only bank charges and failed to adjudicate specific objections on items such as treasury expenses and interest on working capital loans, violating section 144C(5)/(8) and principles of natural justice; the matter was remanded for verification from audited financials, fresh consideration of all objections, and recomputation of arm's length margin. On foreign exchange loss and related brokerage/commission, the disallowance was sustained on merits, but the AO was directed to verify the correct quantum of loss claimed versus disallowed. On section 40(a)(ia), the AO was directed to verify the claim of lower TDS based on certificate and pass orders accordingly, allowing the ground for statistical purposes. - ITAT
On TP adjustment relating to computation of operating margins of selected comparables, the directions were held non-speaking because the panel addressed only bank charges and failed to adjudicate specific objections on items such as treasury expenses and interest on working capital loans, violating section 144C(5)/(8) and principles of natural justice; the matter was remanded for verification from audited financials, fresh consideration of all objections, and recomputation of arm's length margin. On foreign exchange loss and related brokerage/commission, the disallowance was sustained on merits, but the AO was directed to verify the correct quantum of loss claimed versus disallowed. On section 40(a)(ia), the AO was directed to verify the claim of lower TDS based on certificate and pass orders accordingly, allowing the ground for statistical purposes. - ITAT
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