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...
Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party's actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.
Under TNMM, comparability must reflect functional, asset and risk differences, and idle capacity in a start-up ramp-up phase may require adjustment where it distorts net margins. The assessee showed its first full-fledged year of operations, a clear operational ramp-up, improved cost absorption in the next year, and a transparent methodology for the claim; the idle capacity adjustment was therefore allowed in the EPC segment. Working capital adjustment must likewise follow the tested party's actual operating cycle, including relevant operating current assets and liabilities and excluding only non-operating or financial items. Unbilled revenue and material prepayments or advances were treated as operating items, and fresh recomputation was directed subject to verification.
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