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 guarantee commission for SBLC issued for an AE was deleted because benchmarking by external CUP using bank guarantee commission was founded on an incorrect factual premise and, in law, bank guarantees are not comparable to corporate guarantees/SBLC for ALP determination; the assessee's "Other Method" was accepted as ALP. Transfer pricing adjustment on interest on AE loan was deleted as CUP based on the local central bank rate in the borrower's jurisdiction was the appropriate benchmark and the assessee's rate was at arm's length. Addition under s.68 r.w.s. 115BBE for an NBFC loan was deleted since identity, genuineness, and creditworthiness were proved through confirmations and banking trail. Deduction u/s 35(2AB) was allowed as per DSIR certification, brokerage on property sale was allowed as transfer expense, and s.14A disallowance was restricted to dividend-bearing investments. - ITAT
Transfer pricing adjustment on guarantee commission for SBLC issued for an AE was deleted because benchmarking by external CUP using bank guarantee commission was founded on an incorrect factual premise and, in law, bank guarantees are not comparable to corporate guarantees/SBLC for ALP determination; the assessee's "Other Method" was accepted as ALP. Transfer pricing adjustment on interest on AE loan was deleted as CUP based on the local central bank rate in the borrower's jurisdiction was the appropriate benchmark and the assessee's rate was at arm's length. Addition under s.68 r.w.s. 115BBE for an NBFC loan was deleted since identity, genuineness, and creditworthiness were proved through confirmations and banking trail. Deduction u/s 35(2AB) was allowed as per DSIR certification, brokerage on property sale was allowed as transfer expense, and s.14A disallowance was restricted to dividend-bearing investments. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
