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...
Best Judgement Assessment - whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice u/s 143(2) for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of the Act and proceed directly u/s 144 by rejecting the return filed by the Assessee. - HC
Best Judgement Assessment - whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice u/s 143(2) for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of the Act and proceed directly u/s 144 by rejecting the return filed by the Assessee. - HC
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