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 Notice u/s 148 - even assuming that at the time notice was issued the Respondent was not fully aware of all the relevant facts, once the Petitioner submitted its objections drawing his attention to the specific legal position, it was obligatory for the AO to have applied his mind to those points - the fundamental premise that the investment in the shares of its subsidiary amounted to ‘income’ which had escaped assessment was flawed - notice quashed
Reassessment Notice u/s 148 - even assuming that at the time notice was issued the Respondent was not fully aware of all the relevant facts, once the Petitioner submitted its objections drawing his attention to the specific legal position, it was obligatory for the AO to have applied his mind to those points - the fundamental premise that the investment in the shares of its subsidiary amounted to ‘income’ which had escaped assessment was flawed - notice quashed
Note: It is a system-generated summary and is for quick reference only.