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...
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
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