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 under section 40(a)(ia) for alleged non deduction of TDS on contractual payments was rejected after appellate verification of party wise ledgers, TDS returns, certificates and tax audit reports; appellate authority found tax deducted where applicable and set aside the assessing officer's blanket disallowance. Alleged nondisclosure based on Form 26AS entries and invocation of section 145(3) was also rejected because the AO relied on incorrect or double counted figures and ignored reconciliations and the assessee's percentage of completion accounting; the appellate authority's acceptance of reconciliations led to deletion of the addition. Both revenue grounds were dismissed.
Disallowance under section 40(a)(ia) for alleged non deduction of TDS on contractual payments was rejected after appellate verification of party wise ledgers, TDS returns, certificates and tax audit reports; appellate authority found tax deducted where applicable and set aside the assessing officer's blanket disallowance. Alleged nondisclosure based on Form 26AS entries and invocation of section 145(3) was also rejected because the AO relied on incorrect or double counted figures and ignored reconciliations and the assessee's percentage of completion accounting; the appellate authority's acceptance of reconciliations led to deletion of the addition. Both revenue grounds were dismissed.
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