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 the characterisation of gains from sale of shares, the appellate authority accepted documentary evidence showing acquisition in tranches with verifiable dates and costs, and, after a remand report found no discrepancy, held the declared cost and holding period to be correct; the Revenue's plea that the evidence was not before the AO was rejected, and the relief allowing long-term capital loss/confirming short-term capital gain computation was sustained. On salary excess recovered under the Companies Act pursuant to Central Government directions, the recovery was held not to constitute taxable income, following binding precedent, and the addition was deleted. On addition under s.69A for alleged unexplained investment in a US property, the Revenue failed to link the investment to the assessee where family funds and corporate remittance were evidenced; deletion was upheld - ITAT
On the characterisation of gains from sale of shares, the appellate authority accepted documentary evidence showing acquisition in tranches with verifiable dates and costs, and, after a remand report found no discrepancy, held the declared cost and holding period to be correct; the Revenue's plea that the evidence was not before the AO was rejected, and the relief allowing long-term capital loss/confirming short-term capital gain computation was sustained. On salary excess recovered under the Companies Act pursuant to Central Government directions, the recovery was held not to constitute taxable income, following binding precedent, and the addition was deleted. On addition under s.69A for alleged unexplained investment in a US property, the Revenue failed to link the investment to the assessee where family funds and corporate remittance were evidenced; deletion was upheld - ITAT
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