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...
Addition of loss claimed in Future & Options (‘F&O’) - Reliance on statement of third party (Broker) recorded during survey u/s. 133A - it is trite that the statement recorded during survey u/s. 133A cannot be the sole basis on which adverse inference can be drawn against the assessee. The assessee has been kept in the dark and has not been given the entire copy of the statement - there are no other material against the assessee in respect of its transaction in F&O - Additions deleted - AT
Addition of loss claimed in Future & Options (‘F&O’) - Reliance on statement of third party (Broker) recorded during survey u/s. 133A - it is trite that the statement recorded during survey u/s. 133A cannot be the sole basis on which adverse inference can be drawn against the assessee. The assessee has been kept in the dark and has not been given the entire copy of the statement - there are no other material against the assessee in respect of its transaction in F&O - Additions deleted - AT
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