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...
Conversion of limited security to complete security - If the A.O. of the view that there is a potential escapement of income, he may convert the limited scrutiny in to complete scrutiny. But view should be reasonable view based on credible available or material available on record. And in this case, approval of the Pr.CIT/CIT is required and such approval shall be accorded by the Pr.CIT/CIT in writing after being satisfied about merit of the issues. - AT
Conversion of limited security to complete security - If the A.O. of the view that there is a potential escapement of income, he may convert the limited scrutiny in to complete scrutiny. But view should be reasonable view based on credible available or material available on record. And in this case, approval of the Pr.CIT/CIT is required and such approval shall be accorded by the Pr.CIT/CIT in writing after being satisfied about merit of the issues. - AT
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