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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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HC held that reassessment based on seized third-party material requires prima facie material with a live link to the assessee and the alleged escapement of income. A loose paper seized from a broker, which did not name the assessee or contain identifiable particulars, could not by itself support an on-money allegation, especially when the rate was sought to be applied years later through a sale deed record. The broker's statement also did not connect the assessee with the document. The Court said the Revenue must assess the seized material with attendant circumstances and record prima facie relevance; vague, irrelevant and non-specific material could not justify reopening. The reassessment notice was quashed.
HC held that reassessment based on seized third-party material requires prima facie material with a live link to the assessee and the alleged escapement of income. A loose paper seized from a broker, which did not name the assessee or contain identifiable particulars, could not by itself support an on-money allegation, especially when the rate was sought to be applied years later through a sale deed record. The broker's statement also did not connect the assessee with the document. The Court said the Revenue must assess the seized material with attendant circumstances and record prima facie relevance; vague, irrelevant and non-specific material could not justify reopening. The reassessment notice was quashed.
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