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 intra-group IGS/ITSS was deleted because the services were not mere stewardship/shareholder activities and the evidence showed the payments were incurred for business benefit and were at arm's length; consequently, the TPO's NIL ALP determination was unsustainable. Transfer pricing adjustment on marketing support services was also deleted as TNMM, consistently accepted in earlier years, remained the most appropriate method, and CUP was wrongly applied due to lack of stringent functional/product/market comparability. Disallowance of employees' PF contribution for a one-day delay was directed to be rectified as the DRP had already required corrective action, and the AO was ordered to pass a rectification after hearing. CSR-related donation was held eligible for section 80G deduction since section 37 bar does not extend to Chapter VI-A except specified funds; deduction was allowed. - ITAT
Transfer pricing adjustment on intra-group IGS/ITSS was deleted because the services were not mere stewardship/shareholder activities and the evidence showed the payments were incurred for business benefit and were at arm's length; consequently, the TPO's NIL ALP determination was unsustainable. Transfer pricing adjustment on marketing support services was also deleted as TNMM, consistently accepted in earlier years, remained the most appropriate method, and CUP was wrongly applied due to lack of stringent functional/product/market comparability. Disallowance of employees' PF contribution for a one-day delay was directed to be rectified as the DRP had already required corrective action, and the AO was ordered to pass a rectification after hearing. CSR-related donation was held eligible for section 80G deduction since section 37 bar does not extend to Chapter VI-A except specified funds; deduction was allowed. - ITAT
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