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...
Penalty u/s 271(1)(c) - Addition on account of non-genuine gifts - Penalty proceedings are separate and independent. It is an admitted fact that assessee offered the additional income, though, after issuing notice under section 142(1) by AO. Assessee was having in position of certain evidence in the form of declaration, details of donor and PAN number which were furnished the AO. It is also an admitted fact that no efforts were made by AO by issuing any notice to the donor under section 133(6) of the Act or any summon under section 133(1) of the Act. Facts remaining same that a gift received by assessee was treated as non-genuine gift for the want of complete evidence - No penalty - AT
Penalty u/s 271(1)(c) - Addition on account of non-genuine gifts - Penalty proceedings are separate and independent. It is an admitted fact that assessee offered the additional income, though, after issuing notice under section 142(1) by AO. Assessee was having in position of certain evidence in the form of declaration, details of donor and PAN number which were furnished the AO. It is also an admitted fact that no efforts were made by AO by issuing any notice to the donor under section 133(6) of the Act or any summon under section 133(1) of the Act. Facts remaining same that a gift received by assessee was treated as non-genuine gift for the want of complete evidence - No penalty - AT
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