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...
Validity of reopening of assessment u/s 147 - beyond 4 years but within 6 years - Report of the investigation wing might constitute tangible material. The decision to reopen a case on the basis of report of the investigation wing cannot always be condemned or dubbed as fishing and roving inquiry. The expression reasons to believe appearing in section 147 suggest that if the Ld. AO acts as a reasonable and prudent man on the basis of information secured by him that there is a case of reopening, then section 147 can well be pressed into service and assessment can be reopen - AT
Validity of reopening of assessment u/s 147 - beyond 4 years but within 6 years - Report of the investigation wing might constitute tangible material. The decision to reopen a case on the basis of report of the investigation wing cannot always be condemned or dubbed as fishing and roving inquiry. The expression reasons to believe appearing in section 147 suggest that if the Ld. AO acts as a reasonable and prudent man on the basis of information secured by him that there is a case of reopening, then section 147 can well be pressed into service and assessment can be reopen - AT
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