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...
TDR expenditure treated as inventory cost was held allowable in the year to which the AO had himself earlier attributed it; having disallowed it as "prior period" in a later year on the footing that it pertained to the earlier year, the revenue could not take a contradictory stand to deny deduction in both years. The reassessment disallowance was therefore directed to be deleted. Penalty under s. 270A on disallowance of Keyman insurance premium was deleted because the issue was debatable and the AO failed to record the requisite finding specifying whether the case involved under-reporting or misreporting. Disallowance of interest under s. 36(1)(iii) on interest-free advances was deleted since interest-free funds exceeded the advances, attracting the presumption that advances were from such funds - ITAT
TDR expenditure treated as inventory cost was held allowable in the year to which the AO had himself earlier attributed it; having disallowed it as "prior period" in a later year on the footing that it pertained to the earlier year, the revenue could not take a contradictory stand to deny deduction in both years. The reassessment disallowance was therefore directed to be deleted. Penalty under s. 270A on disallowance of Keyman insurance premium was deleted because the issue was debatable and the AO failed to record the requisite finding specifying whether the case involved under-reporting or misreporting. Disallowance of interest under s. 36(1)(iii) on interest-free advances was deleted since interest-free funds exceeded the advances, attracting the presumption that advances were from such funds - ITAT
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