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 14A disallowance was rejected where the assessee's interest free own funds exceeded investments in tax exempt instruments, allowing a presumption those funds financed the investments. Expenditure incurred by overseas branches for NRI desks was held to be head office expenditure meeting the tripartite test and therefore subject to the limitation under the head office expenditure rule. Deduction under the business loss provision for bad and doubtful debts must be given effect before applying the head office expenditure limitation. TDS under the nonresident withholding rule arises only on credit or payment; where neither occurred no disallowance under the TDS penal disallowance rule was warranted. A lump sum transfer without asset wise valuation qualified as a slump sale, so the special net worth capital gains computation applies.
Section 14A disallowance was rejected where the assessee's interest free own funds exceeded investments in tax exempt instruments, allowing a presumption those funds financed the investments. Expenditure incurred by overseas branches for NRI desks was held to be head office expenditure meeting the tripartite test and therefore subject to the limitation under the head office expenditure rule. Deduction under the business loss provision for bad and doubtful debts must be given effect before applying the head office expenditure limitation. TDS under the nonresident withholding rule arises only on credit or payment; where neither occurred no disallowance under the TDS penal disallowance rule was warranted. A lump sum transfer without asset wise valuation qualified as a slump sale, so the special net worth capital gains computation applies.
Note: It is a system-generated summary and is for quick reference only.