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...
Denial of SEIS benefits for FY 2016-17 on the ground that foreign exchange was realized in FY 2017-18 was held unsustainable because the prescribed form expressly permits claiming SEIS for foreign exchange earned in a financial year against services exported in the preceding year, and the relevant criterion is earning/realization of foreign exchange, not the year of export; the rejection order and consequential communication were set aside. Denial of SEIS benefits for components such as travel/transport, inspection, R&D, software, and re-invoicing was also held erroneous since these were integral to the exported engineering services and, once foreign exchange was earned for them, they were eligible; the matter was disposed with directions allowing the claim. - HC
Denial of SEIS benefits for FY 2016-17 on the ground that foreign exchange was realized in FY 2017-18 was held unsustainable because the prescribed form expressly permits claiming SEIS for foreign exchange earned in a financial year against services exported in the preceding year, and the relevant criterion is earning/realization of foreign exchange, not the year of export; the rejection order and consequential communication were set aside. Denial of SEIS benefits for components such as travel/transport, inspection, R&D, software, and re-invoicing was also held erroneous since these were integral to the exported engineering services and, once foreign exchange was earned for them, they were eligible; the matter was disposed with directions allowing the claim. - HC
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