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...
Reassessment u/s 147 - the reasons as they stand should be sufficient to show that on the reasons recorded the AO could have formed the belief that income chargeable to tax has escaped assessment. Once that requirement is fulfilled same can clarify and explain in the affidavit-in-reply and the appraisal report reveals that there was sufficient material for the AO to form the belief - No infirmity in notice u/s 148
Reassessment u/s 147 - the reasons as they stand should be sufficient to show that on the reasons recorded the AO could have formed the belief that income chargeable to tax has escaped assessment. Once that requirement is fulfilled same can clarify and explain in the affidavit-in-reply and the appraisal report reveals that there was sufficient material for the AO to form the belief - No infirmity in notice u/s 148
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