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...
Section 69C was held inapplicable to an ad hoc disallowance of salary and wages recorded in the books, because the "source of such expenditure" stood explained from the regular books and the AO neither alleged out-of-books payments nor an unproved source; at most, the issue concerned allowability under section 37(1) on the ground of alleged excessiveness, so section 69C (and consequential taxation under section 115BBE) could not be invoked, resulting in deletion of the section 69C-based addition. Disallowance of workman and staff welfare expenses was sustained as both Members agreed to confirm it. - ITAT
Section 69C was held inapplicable to an ad hoc disallowance of salary and wages recorded in the books, because the "source of such expenditure" stood explained from the regular books and the AO neither alleged out-of-books payments nor an unproved source; at most, the issue concerned allowability under section 37(1) on the ground of alleged excessiveness, so section 69C (and consequential taxation under section 115BBE) could not be invoked, resulting in deletion of the section 69C-based addition. Disallowance of workman and staff welfare expenses was sustained as both Members agreed to confirm it. - ITAT
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