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...
Reopening beyond four years may be sustained where subsequent survey information indicates bogus purchase and sale transactions and the original assessment did not examine those transactions. Production of records does not establish full and true disclosure when the transactions themselves are allegedly non-genuine, and fresh information with a live nexus to income escaping assessment is not a change of opinion. For unproved business transactions, banking-channel payments alone do not prove genuineness without evidence of physical movement of goods. Where both purchases and corresponding sales are treated as bogus, income should be estimated by applying a gross-profit rate to turnover rather than adding the entire purchases, with credit for profit already disclosed.
Reopening beyond four years may be sustained where subsequent survey information indicates bogus purchase and sale transactions and the original assessment did not examine those transactions. Production of records does not establish full and true disclosure when the transactions themselves are allegedly non-genuine, and fresh information with a live nexus to income escaping assessment is not a change of opinion. For unproved business transactions, banking-channel payments alone do not prove genuineness without evidence of physical movement of goods. Where both purchases and corresponding sales are treated as bogus, income should be estimated by applying a gross-profit rate to turnover rather than adding the entire purchases, with credit for profit already disclosed.
Note: It is a system-generated summary and is for quick reference only.