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...
Assessment u/s 153A - admission made u/s 132(4) - The fundamental difference between evidentiary value of statement under S. 132(4) against the maker of statement vis-a-vis a third party has not been recognised by the revenue. The statement of the maker may possibly operate as estoppel against him in certain circumstances. However, truthfulness thereof is required to be proved beyond doubt for it to bind a third party. The deptt. was duty bound to give cross examination of the maker where it seeks to rely upon it. - AT
Assessment u/s 153A - admission made u/s 132(4) - The fundamental difference between evidentiary value of statement under S. 132(4) against the maker of statement vis-a-vis a third party has not been recognised by the revenue. The statement of the maker may possibly operate as estoppel against him in certain circumstances. However, truthfulness thereof is required to be proved beyond doubt for it to bind a third party. The deptt. was duty bound to give cross examination of the maker where it seeks to rely upon it. - AT
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