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...
Dispute concerned entitlement to deduction under Section 80IC for an Uttarakhand unit: tribunal held the unit's conversion of electrical steel into graded laminations and assembly of an integrated cooling module amounted to 'manufacture' because a commercially distinct commodity with distinct end-use emerged, applying the distinct-commodity test. Prior precedents on transformation and design supported manufacture. The tribunal found no evidence that the unit was formed by splitting-up or reconstruction of existing business and inter-unit transfers were at arm's length; consequently the unit met the conditions of Section 80IC(2)(a) and was not barred by Section 80IC(4)(i), and the assessing officer's disallowance was deleted.
Dispute concerned entitlement to deduction under Section 80IC for an Uttarakhand unit: tribunal held the unit's conversion of electrical steel into graded laminations and assembly of an integrated cooling module amounted to 'manufacture' because a commercially distinct commodity with distinct end-use emerged, applying the distinct-commodity test. Prior precedents on transformation and design supported manufacture. The tribunal found no evidence that the unit was formed by splitting-up or reconstruction of existing business and inter-unit transfers were at arm's length; consequently the unit met the conditions of Section 80IC(2)(a) and was not barred by Section 80IC(4)(i), and the assessing officer's disallowance was deleted.
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