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...
Working capital adjustment in a transfer pricing giving-effect order required proper evidentiary substantiation. The Court noted that the earlier direction to reconsider the claim was not enough because the petitioner failed to comply with the later requisition for working capital details and their impact on profit, and had only furnished an Excel calculation of the adjusted margin. Mere calculations were insufficient; the claim had to be authenticated with supporting documents duly certified by a Chartered Accountant. The matter was therefore remitted for fresh consideration on merits, with liberty to upload the required particulars and an opportunity of hearing before a fresh order was passed.
Working capital adjustment in a transfer pricing giving-effect order required proper evidentiary substantiation. The Court noted that the earlier direction to reconsider the claim was not enough because the petitioner failed to comply with the later requisition for working capital details and their impact on profit, and had only furnished an Excel calculation of the adjusted margin. Mere calculations were insufficient; the claim had to be authenticated with supporting documents duly certified by a Chartered Accountant. The matter was therefore remitted for fresh consideration on merits, with liberty to upload the required particulars and an opportunity of hearing before a fresh order was passed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
